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2884 REVIEW DENIED Although a physician's malpractice may be a proximate cause of complications caused by the subsequent malpractice of another physician in treating the initial injury, Proposition 51 requires a jury to apportion fault regarding the complication; the initial tortfeasor and the second tortfeasor will be jointly and severally liable for all the plaintiff's economic damages, but each will be severally liable only for the non-economic damages attributed to his/her fault.CitationMARINA v SUPERIOR COURT (Serial Malpractice) 84 CA4 435 [See: CivC 1431 etseq; American Motorcycle v Superior Court 20 C3 578; Dewhirst v Leopold 194 C 424; Ash v Mortensen 24 C2 654; Maxwell v Powers 22 CA4 1596, T/AT 4/94]
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