In Carr v. Cove (1973) 33 Cal.App.3d 851, the plaintiff suffered injuries in an automobile collision. Two months later, she was again injured in a second collision. The plaintiff filed suit against both drivers, and settled her personal injury claim with the driver in the first accident for $ 50,000. Trial proceeded against the second driver, and the jury awarded the plaintiff $ 35,000. The trial court rejected the second driver's request to offset the jury's award with the earlier settlement. The appellate court in Carr affirmed, noting Code of Civil Procedure section 877 "works to prevent settlements from producing double recoveries in the case of a single injury caused by joint tortfeasors. The general theory of compensatory damages bars double recovery for the same wrong. The principal situation is where joint or concurrent tortfeasors are jointly and severally liable for the same wrong." (Carr, supra, 33 Cal.App.3d at p. 854, original italics.) The court determined that "ordinarily, no danger of a double recovery exists where separate tortfeasors cause separate injuries." (Ibid.)