Stitt v. Mahaney

272 N.W.2d 526, 403 Mich. 711, 1978 Mich. LEXIS 408
CourtMichigan Supreme Court
DecidedDecember 22, 1978
Docket59150, (Calendar No. 1)
StatusPublished
Cited by25 cases

This text of 272 N.W.2d 526 (Stitt v. Mahaney) is published on Counsel Stack Legal Research, covering Michigan Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Stitt v. Mahaney, 272 N.W.2d 526, 403 Mich. 711, 1978 Mich. LEXIS 408 (Mich. 1978).

Opinion

Ryan, J.

I agree that plaintiff is entitled to a new trial. However, I do not agree with Justice Williams’ answer to the first question posed in this case. The release of the original tortfeasor was relevant to this suit against these alleged successive tortfeasors and was properly admitted in evidence.

I. Admissibility of the Release

I do not agree that the language of the printed release form under consideration clearly limits the release to the original tortfeasors. The language of the document of release explicitly releases, acquits and forever discharges any and all persons, firms and corporations from any and all actions, claims and all consequential damages in any way growing out of the injuries resulting from the original accident. 1 The "boiler plate” language employed is that generally found in printed release forms for general application and its meaning is unclear. On its face it could be interpreted to release defend *718 ants, although it could also reasonably be interpreted as a release solely of the liability for injuries suffered in the original accident. Both interpretations are plausible. The question thus becomes one of determining the intention of the parties to the release.

Seeking to determine the intention of the parties to the release comports with the modern trend in this area of the law which is that the determination of whether a release of an original tortfeasor constitutes a bar to an action against the treating physician is a question of the intention of the parties to the release. 39 ALR3d 260, § 2[a], p 265 and § 8, p 281. The question of the intention of the parties, where the language of the release is ambiguous, is normally one to be determined by the trier of fact.

The language of the printed release form used in this case was susceptible to conflicting interpretations, one of which plausibly would extend its terms to defendants. Consequently, it was necessary to determine the intention of the parties to the release. The document of release was relevant to this determination and, therefore, properly admissible in evidence. The factual determination of the parties’ intention was properly left to the jury, with appropriate instructions. 2

*719 II. Deduction of Amount Received From Original Tortfeasor From Potential Recovery Against Defendants

I agree that the trial court erred by instructing the jury that the law required a deduction of the prior settlement with the original tortfeasor from the damages, if any, found owing by defendants.

Because the jury instructions on this issue were erroneous, I would remand for a new trial with direction to the trial judge to properly instruct the jury on the permissible deductibility of all or part of the settlement in accordance with the substance of the instructions suggested by Justice Williams.

Kavanagh, C.J., and Coleman and Fitzgerald, JJ., concurred with Ryan, J.

Williams, J.

This case raises the question of whether the release of a tortfeasor causing injuries through an automobile accident is necessarily relevant to a suit against successive and independent tortfeasors who render negligent medical attention. It also raises the question as to the propriety of a court instruction that the prior consideration from the original tortfeasor should be deducted from any liability of the subsequent tortfeasors. We hold that the prior release was not relevant to the suit against the successive and independent *720 tortfeasors and that whether a deduction is appropriate is a question of fact.

I. Facts

On July 5, 1970, plaintiff Daniel Joseph Stitt was riding a motorcycle to his place of employment when he was seriously injured in a collision with an automobile. Stitt was taken to the Holland City Hospital where he ultimately spent 7-1/2 weeks recovering from his injuries. We adopt the following facts from the Court of Appeals opinion which enumerate the injuries and the basis of this cause of action in medical malpractice, 72 Mich App 120, 123-124; 249 NW2d 319 (1976).

"Plaintiff was * * * taken in critical condition and great pain to the emergency room at the defendant city’s hospital. Defendant Dr. DeWitt, plaintiff’s family physician, met him at the hospital and ordered numerous X-rays. Dr. DeWitt summoned defendant Dr. Mahaney, an orthopedic surgeon, who assumed care of the patient, reviewed the X-rays, and, pursuant thereto, ordered traction of the right leg in treatment of an apparent fracture of the right acetabulum (hip socket).
"Unbeknownst to Dr. Mahaney, a hospital technician had mislabeled an X-ray: plaintiff was actually suffering a fracture of his left hip. This error was discovered on the next day by defendant Dr. Gesink, a radiologist, who corrected the X-ray label and dictated a report for Drs. Mahaney and DeWitt with a copy for plaintiff’s file. For some reason, Dr. Mahaney did not become aware of the error until his request for follow-up X-rays 11 days later. Traction remained for this period on the 'wrong’ leg.”

The defendants concede the mistake but assert that Stitt was not damaged thereby.

Two years after the accident, Stitt’s father, as *721 guardian for his then minor son, settled the negligence claim against the driver of the automobile for approximately $7500, including medical expenses, and executed a general release.

Subsequently, the instant action for damages resulting from the mislabeling of the X-ray was brought against Stitt’s family doctor (Donald E. DeWitt, M.D.), 1 the orthopedic surgeon (Robert C. Mahaney, M.D.), the X-ray service company (Owen J. Gesink, doing business as C. P. Truog & Associates), and the City of Holland (owner of the hospital).

The trial court allowed into evidence, over objection of plaintiff, the release executed by Stitt’s father. The court instructed the jury as to the release as follows:

"* * * It is also his claim [Dr. Mahaney] that a settlement was made in the sum of $7,021.41, by the signing of a general release, and that general release, given in the course of that settlement, was a complete settlement of damages and injuries and bars the plaintiff from recovery from any of the defendants in this *722 lawsuit. Dr. Mahaney claims he is entitled to a judgment in his favor.”
"* * * Finally Dr. Gesink claims that the release given by the plaintiff to the automobile driver was intended to release him, as well.”
"* * * It is also the City’s position that plaintiff, in fact, sustained no additional injuries or aggravations of his accident injuries because of what happened, and that the hospital, as well as the other defendants, were intended to be released by the release received in evidence.”

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Bluebook (online)
272 N.W.2d 526, 403 Mich. 711, 1978 Mich. LEXIS 408, Counsel Stack Legal Research, https://law.counselstack.com/opinion/stitt-v-mahaney-mich-1978.