Spangler v. McQuittyAnnotate this Case
Respondents, on behalf of their minor child, Dylan, sued Petitioners after Dylan received severe injuries during his birth. The jury returned a verdict in favor of Dylan. Ultimately the court reduced the judgment to approximately $5 million. Petitioners satisfied the judgment. After Dylan died, Respondents filed a wrongful death action against Petitioners based on the same underlying facts in the personal injury action. The circuit court dismissed Respondents’ wrongful death action, concluding that the action was barred by a judgment in Dylan’s personal injury action. The Court of Special Appeals reversed. The Court of Appeals affirmed, holding (1) Maryland’s wrongful death statute creates a new and independent cause of action for a decedent’s beneficiaries, and therefore, a judgment on the merits in a decedent’s personal injury action during his lifetime does not bar a subsequent wrongful death action by the beneficiaries; and (2) a release by the injured person of one joint tortfeasor, whether before or after the judgment, does not discharge the other tortfeasors unless the release so provides.