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Keywords

tortliabilityappealtrialsummary judgmentmalpracticeleasecorporationsustainedrehabilitation

settlementtortliabilityappealtrialmotionsummary judgmentmalpracticeleasecorporationsustainedrehabilitation

Related Cases

Lujan v. Healthsouth Rehabilitation Corp., 120 N.M. 422, 902 P.2d 1025, 1995 -NMSC- 057

Facts

Irene Lujan sued Nancy Jaramillo for injuries sustained by her son Martin in a motorcycle accident. After settling the suit and signing a release in February 1991, Lujan later sued Healthsouth Rehabilitation Corporation for medical malpractice, alleging that an employee negligently refractured Martin's leg during treatment. Healthsouth argued that the release barred Lujan's claims, leading to a summary judgment in their favor, which was affirmed by the Court of Appeals.

Irene Lujan sued Nancy Jaramillo for injuries that Lujan's son Martin sustained in a motorcycle collision with Jaramillo's automobile on January 27, 1990. In settlement of that suit, Lujan signed a release of claims in February 1991. In March 1993 Lujan sued Healthsouth Rehabilitation Corporation, Healthsouth of New Mexico, Inc., and Mercedes Chavez (collectively, “Healthsouth”) for medical malpractice in connection with treatment of the femoral fracture that Martin suffered in the accident with Jaramillo. Healthsouth moved for summary judgment, arguing that the release signed by Lujan in settlement of her suit against Jaramillo barred her medical malpractice claims. The trial court granted Healthsouth's motion, and the Court of Appeals affirmed.

Issue

Does a general release of a named tortfeasor bar a subsequent malpractice claim against a medical care provider for negligent treatment arising from the same injury?

Rule

A general release of a tortfeasor who causes an injury requiring medical treatment does not, as a matter of law, also release an allegedly negligent medical care provider.

General release of a tortfeasor who causes an injury that requires medical treatment does not as a matter of law also release an allegedly negligent medical care provider.

Analysis

The court analyzed the language of the release and determined that it did not explicitly include claims against Healthsouth, as the release was specific to the injuries arising from the January 1990 accident. The court concluded that Healthsouth's liability for the enhanced injury was separate and distinct from the original injury caused by Jaramillo, thus the release did not bar Lujan's malpractice claims.

Conclusion

The Supreme Court reversed the trial court's decision, holding that the general release did not preclude Lujan from pursuing her malpractice claims against Healthsouth.

Who won?

Irene Lujan prevailed in the case because the Supreme Court found that her release of Jaramillo did not encompass her claims against Healthsouth for negligent treatment.

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