The matter proceeded to trial in the Circuit Court for Baltimore City, against the only remaining defendant, Dr. Hashmi. The jury found that Dr. Hashmi was negligent in his care and treatment of Mr. Bennett and that the doctor’s negligence was the cause of Mr. Bennett’s death. The jury awarded $2,295,000 in damages to the estate. The judgment was reduced, pursuant to Maryland’s cap on damages, to $1,795,000. Dr. Hashmi sought to have the judgment further reduced by four-fifths pursuant to the Maryland Uniform Contribution Among Joint Tort-Feasors Act ("UCATA"), MD. CODE ANN., CTS. & JUD. PROC. § 3-1401 et seq. Specifically, Dr. Hashmi argued that he was only responsible for one-fifth of the judgment because Good Samaritan’s employees were separate tortfeasors and not included under the umbrella of Good Samaritan’s
release.

The trial court disagreed with Dr. Hashmi and held that the estate had entered into settlement agreements with two other defendants, Good Samaritan and E.P.A.; therefore, the trial court reduced the judgment by two-thirds. Dr. Hashmi appealed the trial court’s judgment.

The UCATA provides, in part, that a release by the injured person of one joint tortfeasor reduces the claim against the other joint tortfeasors in the amount of the consideration paid for the release or proportion by which the release provides that the total claim shall be reduced. Ascertaining the number joint tortfeasors is critical, therefore, in determining the amount by which the jury award must be reduced before the judgment is entered.

Dr. Hashmi argued that the language of the Good Samaritan release established that Good Samaritan accounted for three joint tortfeasor shares, one for each of its three allegedly negligent employees. He contended that the language of the release shows that the parties intended to release only Good Samaritan, not the individual employees whose care was at issue. Therefore, Dr. Hashmi argued, the trial court should have reduced the verdict by five shares, rather than three shares. The Court of Special Appeals held that the settlement with Good Samaritan accounted for one joint tortfeasor share, and included the allegedly negligent employees in that single share. Good Samaritan's staff were members of the class of individuals (e.g., "employees, staff, resident, physicians") who were explicitly included in the definition of released party.

1 One of the defendant physicians was dismissed with prejudice, but without a settlement agreement. The other defendant physician, an employee of E.P.A., was released pursuant to E.P.A.’s joint-tortfeasor release, which undisputedly created one joint-tortfeasor share.