One Satisfaction Rule, Damages

A plaintiff is entitled to “one satisfaction” of the same wrong. Echols v. City of Riverside, 332 S.W.3d 207, 212 (Mo. Ct. App. 2010). In other words, while a plaintiff may pursue damages from different parties and sources, the plaintiff cannot recover more than the plaintiff’s damages and thereby be put in a better condition than he or she would have had the wrong not been committed. Ozark Air Lines, Inc. v. Valley Oil Co., LLC, 239 S.W.3d 140, 147 (Mo. Ct. App. 2007). A party should not receive a “double recovery.” Echols, 332 S.W.3d at 212.

When applicable, and as a way to reduce damages, a defendant will usually argue an offset or the one satisfaction rule as an affirmative defense. To succeed on this defense, the defendant must show an overlap between: (1) the injuries or damages for which the plaintiff received damages/compensation and that (2) the injuries or damages are the subject of a plaintiff’s claim against the defendant.

Because many civil lawsuits are settled, an offset defense payment on a settlement payment is possible, though more analysis is required. Specifically, how the parties intended the settlement to be allocated is a question of fact that itself may require a trial determination. Moore Auto Grp., Inc. v. Lewis, 362 S.W.3d 462 (Mo. Ct. App. 2012).