Aidan Ming-Ho Leung, a Minor v. Verdugo Hills Hospital, Defendant and Appellant

Summary

The court repudiated California's common law release rule, holding that a settlement with one joint tortfeasor does not automatically release nonsettling tortfeasors from liability. Because the settlement was not made in good faith, the court adopted setoff with contribution: the settlement is credited against the judgment, while nonsettling tortfeasors remain jointly and severally liable and may seek contribution. The court also held that substantial evidence supported the jury's finding that the hospital's negligence legally caused the child's injuries and reversed for consideration of unresolved issues.