Sakellariadis v. Campbell
Illinois Court of Appeals
909 N.E.2d 353 (2009)
Gloria Sakellariadis (plaintiff) was injured in two car accidents three months apart, one involving Steven Campbell (defendant) and the other Bruce Walters (defendant), both allegedly causing injury to the same part of her body; she sued both in one suit and requested a jury form allocating each defendant's responsibility across 14 damage categories. After she settled with Campbell for $150,000 mid-deliberation, the jury awarded $518,000 total damages and allocated 50% responsibility to each defendant; the trial court entered judgment against Walters for 50%, and Sakellariadis appealed, arguing Walters should owe the full remaining balance under joint and several liability.
Whether the doctrine of joint and several liability applies if two or more persons cause a single, indivisible injury through concurrent negligence.