In Carter v. Wallace & Gale Asbestos Settlement Trust, 96 A.3d 147 (Md. 2014) (No. 84), the Maryland Court of Appeals (Maryland’s highest court) rejected an argument that damages should be apportioned among parties responsible for contributing to the underlying injury of plaintiff’s decedent in a wrongful death case. Plaintiff sued the manufacturer of asbestos to which he’d been exposed at work for injuries resulting from lung cancer. The plaintiff died while the lawsuit was pending, and his family members added a claim for wrongful death to the lawsuit. Because plaintiff was a lifelong smoker, the asbestos defendant blamed tobacco manufacturers for a substantial portion of the wrongful death damages and urged apportionment of those damages. The Maryland Court of Appeals rejected the argument, holding that Maryland’s common law allowed the plaintiff to sue one defendant for the full amount of damages where that defendant was a substantial factor in causing plaintiff’s injury, even if another party wrongfully contributed to the harm, unless the record reflects a factual basis for apportionment. Because Maryland law views death as an indivisible injury, wrongful death damages cannot be apportioned. Consequently, the court affirmed the trial court’s entry of judgment against the defendant for the entire amount of plaintiff’s wrongful death damages.