Hanley v. Mazda Motor Corporation2/4/2000
FOR PUBLICATION
Updated Copy April 14, 2000
On the basis of alleged injuries sustained in an automobile accident, plaintiff filed a complaint against defendants herein in August 1995. Approximately one year earlier, with regard to the same incident and resultant injuries, plaintiff had filed a complaint against Ford Motor Company. In that suit, Ford made an offer of judgment, the plaintiff accepted the offer of judgment, a judgment was entered, and Ford satisfied the judgment. In the instant case, the trial court granted summary disposition in favor of defendants Mazda Motor Corporation and AutoAlliance International, Inc. (collectively Mazda), concluding that under the unique facts in these suits, satisfaction of the previous judgment bars plaintiff from further recovery. The question on appeal is whether satisfaction of a judgment entered pursuant to the offer of judgment rule, MCR 2.405, precludes a plaintiff from seeking from other tortfeasors additional damages arising from the same incident and injuries. We hold that a judgment entered pursuant to the acceptance of an offer of judgment under MCR 2.405 functions as a full and final adjudication on the merits, and, therefore, satisfaction of a judgment so entered precludes a plaintiff from further relief from other alleged joint tortfeasors.
I.
In this products liability action, plaintiff sued the named defendants for injuries he suffered in an automobile accident. Plaintiff alleged that another vehicle struck his car, a 1989 Ford Probe, causing him to suffer injuries and, among other things, that his car was defective because, upon collision, an inadequate hinge mechanism allowed the hood to penetrate the plane of the windshield. Plaintiff's car was the product of a joint venture between Mazda and Ford. Mazda designed and manufactured the Ford Probe, and Ford marketed the car.
Previously, plaintiff sued Ford with regard to this same incident and the resultant injuries. In that case, on September 6, 1995, plaintiff accepted Ford's offer of judgment in the amount of $200,000. The trial court entered the judgment on October 30, 1995. Thereafter, Ford satisfied the judgment. However, on August 11, 1995, just twenty six days before accepting the offer of judgment, plaintiff initiated this action against Mazda, seeking further damages.
The trial court denied Mazda's initial motion for summary disposition, which claimed that the action was barred under the doctrine of res judicata. Nevertheless, the trial court allowed Mazda's subsequent motion to amend its affirmative defenses to include an argument that, under the contribution statute, MCL 600.2925c(5); MSA 27A.2925(3)(5), plaintiff was entitled to only one satisfaction of a judgment for his injuries. Thereafter, Mazda moved for summary disposition under MCR 2.116(C)(7) and (10), arguing that on the basis of the satisfaction of the judgment against Ford in the previous suit, they, as joint tortfeasors with Ford, were discharged from liability. The trial court agreed, under the unique facts of these suits, and dismissed the case. This appeal follows.
II.
We review a trial court's grant of summary disposition de novo. Spiek v Dep't of Transportation, 456 Mich 331, 337; 572 NW2d 201 (1998); Russell v Dep't of Corrections, 234 Mich App 135, 136; 592 NW2d 125 (1999). MCR 2.116(C)(7) permits summary disposition where the claim is barred because of, among other things, prior judgment. In reviewing a motion under MCR 2.116(C)(7), this Court accepts as true the plaintiff's well-pleaded allegations, construing them in the plaintiff's favor. Abbott v John E Green Co, 233 Mich App 194, 198; 592 NW2d 96 (1998). We must
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