joint and several liability doctrine (West Virginia) · Go Syfert
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joint and several liability doctrine in West Virginia

7 West Virginia opinions name it 1 courts 1988–2015 0 in the last five years

The cases below were cited by West Virginia courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (5)

CaseFollowedCited
Sitzes v. Anchor Motor Freight, Inc.green
wva · 1982 · cited in 5 West Virginia opinions naming this issue, 1988–2015
2 sentences

2015“The basic purpose of the joint and several liability rule is to permit the injured plaintiff to select and collect the full amount of his damages against one or more joint tortfeasors.” Id. at 707 , 289 S.E.2d at 685 (emphasis added).

2015“The basic purpose of the joint and several liability rule is to permit the injured plaintiff to select and collect the full amount of his damages against one or more joint tortfeasors.” Id. at 707 , 289 S.E.2d at 685 (emphasis added).

35
Estate of Williams Ex Rel. Williams v. Vandeberggreen
sd · 2000 · cited in 1 West Virginia opinions naming this issue, 2001–2001
2 sentences

2001These courts take the position that because “vicarious liability derives solely from the principal’s legal relation to the wrongdoer, settlement with the tort-feasor removes the basis for any additional recovery from the principal upon the same acts of negligence.” Id.; see also Estate of Williams v. Vandeberg, 620 N.W.2d 187, 190 (S.D.2000); Theophelis, 430 Mich. at 490-91 , 424 N.W.2d at 486 (plurality opinion).

2001These courts take the position that because "vicarious liability derives solely from the principal's legal relation to the wrongdoer, settlement with the tortfeasor removes the basis for any additional recovery from the principal upon the same acts of negligence." Id.; see also Estate of Williams v. Vandeberg, 620 N.W.2d 187, 190 (S.D.2000); Theophelis, 430 Mich. at 490-91 , 424 N.W.2d at 486 (plurality opinion).

11
Biddle v. Sartori Memorial Hospitalgreen
iowa · 1994 · cited in 1 West Virginia opinions naming this issue, 2001–2001
2 sentences

2001Some courts have, in accord with this reasoning, stressed the "fundamental distinction between the full recovery permitted under the doctrine of joint and several liability, and the limitations inherent in a claim that *914 rests on the doctrine of vicarious liability." Biddle v. Sartori Mem'l Hosp., 518 N.W.2d 795, 798 (Iowa 1994).

2001The Iowa Supreme Court acknowledged the "fundamental distinction between the full recovery permitted under the doctrine of joint and several liability, and the limitations inherent in a claim that rests on the doctrine of vicarious liability." Id. at 798 .

11
Theophelis v. Lansing General Hospitalgreen
mich · 1988 · cited in 1 West Virginia opinions naming this issue, 2001–2001
2 sentences

2001These courts take the position that because "vicarious liability derives solely from the principal's legal relation to the wrongdoer, settlement with the tortfeasor removes the basis for any additional recovery from the principal upon the same acts of negligence." Id.; see also Estate of Williams v. Vandeberg, 620 N.W.2d 187, 190 (S.D.2000); Theophelis, 430 Mich. at 490-91 , 424 N.W.2d at 486 (plurality opinion).

2001These courts take the position that because "vicarious liability derives solely from the principal's legal relation to the wrongdoer, settlement with the tortfeasor removes the basis for any additional recovery from the principal upon the same acts of negligence." Id.; see also Estate of Williams v. Vandeberg, 620 N.W.2d 187, 190 (S.D.2000); Theophelis, 430 Mich. at 490-91 , 424 N.W.2d at 486 (plurality opinion).

11
Bradley v. Appalachian Power Co.green
wva · 1979 · cited in 1 West Virginia opinions naming this issue, 1988–1988
2 sentences

1988This Court pointed out in Bradley v. Appalachian Power Co., 163 W.Va. 332, 344 , 256 S.E.2d 879, 886 (1979), that the newly adopted comparative negligence rule would not alter the doctrine of joint and several liability.

1988This Court pointed out in Bradley v. Appalachian Power Co., 163 W.Va. 332, 344 , 256 S.E.2d 879, 886 (1979), that the newly adopted comparative negligence rule would not alter the doctrine of joint and several liability.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in West Virginia. Read the followed side critically anyway.

Also cited on this issue (5)

CaseCitedYears
Tennant v. Marion Health Care Foundation, Inc. green
wva · 1995
2 sentences

2014Syllabus Point 6, Tennant v. Marion Health Care Foundation, Inc., 194 W.Va. 97 , 459 S.E.2d 374 (1995). .

2014Syllabus Point 6, Tennant v. Marion Health Care Foundation, Inc., 194 W.Va. 97 , 459 S.E.2d 374 (1995). .

12014–2014
Kodym v. Frazier green
wva · 1991
2 sentences

2004Appellant maintains, however, that our decisions in cases such as Biro v. Fairmont General Hospital, Inc., 184 W.Va. 458 , 400 S.E.2d 893 (1990), which relied on syllabus point four of Butler v. Smith's Transfer Corporation, 147 W.Va. 402 , 128 S.E.2d 32 (1962), and Kodym v. Frazier, 186 W.Va. 221 , 412 S.E.2d 219 (1991), limits the term joint tortfeasors to multiple defendants whose concurrent negligence has caused injury to the plaintiff.

2004Appellant maintains, however, that our decisions in cases such as Biro v. Fairmont General Hospital, Inc., 184 W.Va. 458 , 400 S.E.2d 893 (1990), which relied on syllabus point four of Butler v. Smith's Transfer Corporation, 147 W.Va. 402 , 128 S.E.2d 32 (1962), and Kodym v. Frazier, 186 W.Va. 221 , 412 S.E.2d 219 (1991), limits the term joint tortfeasors to multiple defendants whose concurrent negligence has caused injury to the plaintiff.

12004–2004
Biro v. Fairmont General Hospital, Inc. green
wva · 1990
2 sentences

2004Appellant maintains, however, that our decisions in cases such as Biro v. Fairmont General Hospital, Inc., 184 W.Va. 458 , 400 S.E.2d 893 (1990), which relied on syllabus point four of Butler v. Smith's Transfer Corporation, 147 W.Va. 402 , 128 S.E.2d 32 (1962), and Kodym v. Frazier, 186 W.Va. 221 , 412 S.E.2d 219 (1991), limits the term joint tortfeasors to multiple defendants whose concurrent negligence has caused injury to the plaintiff.

2004Appellant maintains, however, that our decisions in cases such as Biro v. Fairmont General Hospital, Inc., 184 W.Va. 458 , 400 S.E.2d 893 (1990), which relied on syllabus point four of Butler v. Smith's Transfer Corporation, 147 W.Va. 402 , 128 S.E.2d 32 (1962), and Kodym v. Frazier, 186 W.Va. 221 , 412 S.E.2d 219 (1991), limits the term joint tortfeasors to multiple defendants whose concurrent negligence has caused injury to the plaintiff.

12004–2004
Butler v. Smith's Transfer Corp. green
wva · 1962
2 sentences

2004Appellant maintains, however, that our decisions in cases such as Biro v. Fairmont General Hospital, Inc., 184 W.Va. 458 , 400 S.E.2d 893 (1990), which relied on syllabus point four of Butler v. Smith's Transfer Corporation, 147 W.Va. 402 , 128 S.E.2d 32 (1962), and Kodym v. Frazier, 186 W.Va. 221 , 412 S.E.2d 219 (1991), limits the term joint tortfeasors to multiple defendants whose concurrent negligence has caused injury to the plaintiff.

2004Appellant maintains, however, that our decisions in cases such as Biro v. Fairmont General Hospital, Inc., 184 W.Va. 458 , 400 S.E.2d 893 (1990), which relied on syllabus point four of Butler v. Smith's Transfer Corporation, 147 W.Va. 402 , 128 S.E.2d 32 (1962), and Kodym v. Frazier, 186 W.Va. 221 , 412 S.E.2d 219 (1991), limits the term joint tortfeasors to multiple defendants whose concurrent negligence has caused injury to the plaintiff.

12004–2004
Luna v. Shockey Sheet Metal & Welding Co. green
idaho · 1987
2 sentences

1999Luna, 113 Idaho at 196 , 743 P.2d at 64 .

1999Luna, 113 Idaho at 196 , 743 P.2d at 64 .

11999–1999

Statutes the citing opinions construe

WV § W. Va. Code § 55-7-13 (3) WV § W. Va. Code § 55-7B-9 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 31 (1978–2025) FL 25 (1985–2022) IL 24 (1983–2026) TN 20 (1995–2023) CT 9 (1990–2000) IA 9 (1983–2020) AZ 8 (1987–2003) WV 7 (1988–2015) NM 6 (1983–2001) NY 5 (1993–2015) WI 5 (1980–2009) ND 5 (1983–1989) HI 4 (1998–2012) PA 4 (2007–2021) MI 4 (1982–2015) WY 3 (1981–1987) MN 3 (1986–2013) OH 3 (2011–2025) MT 3 (1987–1990) VI 2 (1992–2017) NH 2 (2006–2011) AK 2 (1979–2023) WA 2 (1978–1983) ID 2 (1979–1987)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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