Bundt v Embro
S. Ct NY [1965]
Author:- Sam Biers

Satisfaction and Release

Relevant Facts: 5 Pls were passengers in one or the other of 2 cars that collided.  The actions were against the owners and drivers, as well as the contractor repairing the highway who had negligently obstructed the view of a stop sign. Pls had recovered a judgment in the Ct of Claims against the State of NY.

Legal Issue(s): Whether the rule that satisfaction of judgment against one joint tort-feasor discharges the others applies to a Court of Claims judgment and prevents party whose Court of Claims judgment has been satisfied from obtaining separate recovery from joint tort- feasors with the state?

Court’s Holding: Yes

Procedure: Dfs moved to amend their answers to include the defense of satisfaction and discharge; Leave granted.

Law or Rule(s): One who has been injured by the joint wrong of several parties may recover his damages against either or all; but Satisfaction of judgment against one joint tort-feasor discharges the others.

Court Rationale: Although there may be many wrongdoers, the act and the consequence are indivisible.   The ACT states that the state waives its immunity from liability and places itself as to those making claims against the State, in the same position as a private individual.  That ct determined the State was negligent and awarded Pl damages.  If the Dfs are joint tort feasors w/ the state then that judgment as satisfied should prevent double recovery for a single injury.  If the trial ct determines that the Dfs were in fact joint tort feasors w/ the state, the satisfaction against the State would operate as a discharge of the Dfs.

Plaintiff’s Argument: The rule of satisfaction has no application to a Ct of Claims judgment against the State.

Defendant’s Argument: The judgment relating to one single event around the injury was satisfied by the State of NY, double recovery should be barred.