Samara v. Matar

Dr. Haitham Matar (defendant) recommended that Rana Samara (plaintiff) receive a dental implant for a missing tooth. Dr. Stephen Nahigian (defendant) performed Samara’s dental-implant surgery. Samara sued Matar and Nahigian for professional negligence, arguing that Matar was vicariously liable for her injury, which was allegedly due to Nahigian’s negligence. The trial court granted summary judgment for Nahigian, finding that Samara’s claim was barred by the statute of limitations and that Nahigian did not cause Samara’s injury. Samara appealed and sought review of the causation issue. The appellate court affirmed the trial court’s judgment on statute-of-limitations grounds without reviewing the causation issue. After the trial court entered judgment for Nahigian, Matar moved for summary judgment. The court gave its prior causation determination preclusive effect and granted summary judgment on the basis that Matar could not be held vicariously liable for Nahigian’s alleged negligence if Nahigian’s negligence did not cause Samara’s injury. Samara appealed, arguing that the appellate court’s affirmance only operated as collateral estoppel with respect to the ground reviewed on appeal. The appellate court ruled in Samara’s favor. Matar appealed to the California Supreme Court, arguing that collateral estoppel should apply because a trial court’s judgment is presumed to be correct, and that applying collateral estoppel would promote judicial economy.