This Note explores the Tegman decision in the context of joint and several liability between negligent and intentional actors within Washington State. Part II places Washington tort law into perspective, including the doctrine of joint and several liability, both before and after the Tort Reform Act of 1986. Part III discusses the Tegman decision, methods used in other jurisdictions for dealing with similar situations, and potential solutions to the problems posed by the Tegman holding. Finally, Part IV concludes and urges both the court to reconsider its ruling in Tegman and the legislature to clarify its intent.
Victor J. Torres, Tegman v. Accident & Medical Investigations, Inc.: The Re-Modification of Modified Joint and Several Liability by Judicial Fiat, 29 SEATTLE U. L. REV. 729 (2006).