Bundt v. Embro
48 Misc. 2d 802, 265 N.Y.S.2d 872, 1965 N.Y. Misc. LEXIS 1294 (1965)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
The satisfaction of a judgment against one joint tortfeasor operates as a discharge of all other joint tortfeasors for the same indivisible injury. This rule applies even when the judgment was rendered against the State in the Court of Claims, as the State's waiver of sovereign immunity places it in the same position as a private defendant.
Facts:
- An automobile operated by Edward Embro, Jr. collided with an automobile operated by Aldo Di Belardino.
- Plaintiff Bundt was a passenger in Embro's car, and plaintiffs Mondini were passengers in Di Belardino's car.
- At the time of the accident, defendant Peckham Road Corporation was performing road repairs near the scene.
- The plaintiffs allege that Peckham negligently obstructed the view of a stop sign, which Embro's car passed just before the collision.
- The plaintiffs claim that the negligence of both drivers and Peckham jointly caused the accident and their resulting injuries.
Procedural Posture:
- Plaintiffs Bundt and Mondini instituted an action against the State of New York in the Court of Claims.
- The Court of Claims rendered a judgment in favor of the plaintiffs and against the State.
- The judgment from the Court of Claims was fully satisfied.
- Plaintiffs then brought a separate action in the Supreme Court against defendants Peckham, Embro, and others for personal injuries from the same accident.
- The defendants moved in the Supreme Court for leave to amend their answers to interpose the affirmative defense of discharge and satisfaction, based on the satisfied Court of Claims judgment.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does the full satisfaction of a judgment obtained against the State in the Court of Claims discharge other alleged joint tortfeasors from liability for the same injury?
Opinions:
Majority - William B. Groat, J.
Yes, the satisfaction of a judgment against the State discharges other joint tortfeasors. It is a long-standing legal principle that while an injured party may sue and recover judgments against multiple joint tortfeasors, there can be only one satisfaction for a single injury. The law does not permit a double recovery. General Obligations Law § 15-102 allows a plaintiff to obtain multiple judgments, but does not abrogate the common-law rule that satisfaction of one discharges all. The court rejected the argument that a judgment from the Court of Claims is an exception; the Court of Claims Act explicitly waives the State's sovereign immunity and provides that liability is determined by the same rules of law applicable to private individuals. Therefore, the State can be a joint tortfeasor, and if it is proven that the defendants were in fact joint tortfeasors with the State, the satisfaction of the judgment against the State would operate as their discharge.
Analysis:
This decision reaffirms the vitality of the common law "one satisfaction rule" in New York tort law, clarifying its application in the modern statutory era. It establishes that the waiver of sovereign immunity makes the State fully equivalent to a private party for the purposes of joint tortfeasor liability rules. The ruling prevents plaintiffs from leveraging a satisfied judgment against one party (here, the State) to secure a second, potentially larger, recovery from other responsible parties for the same harm. This reinforces the principle that tort damages are compensatory, not punitive, aiming to make the plaintiff whole only once.
