In Biddle v. Sartori Mem. Hosp., 518 N.W.2d 795 (Iowa 1994), a female emergency patient was negligently released from the hospital by her doctor. She died later that day from heart failure. The legal representative of the plaintiff/patient released the doctor from liability after a substantial settlement had been reached. Her estate then sued the hospital claiming that it was vicariously liable for the doctor's negligence. The Iowa Supreme Court determined that without independent negligence alleged by the plaintiff or it being alleged as a joint tortfeasor case, the plaintiff failed to address "the limitations inherent in a claim that rests on the doctrine of vicarious liability." Biddle, supra, at 798. Like the Supreme Court of North Dakota, the Iowa court went on to articulate vicarious liability this way: "The "percentage of negligence" attributable to the conduct of the servant constitutes the entire "single share" of liability attributable jointly to the master and servant.. .. Because this percentage of negligence represents the "single share" of liability covered by the common liability of the master and servant, the master is necessarily released from vicarious liability for the released servant's misconduct." Id. The Iowa court went on to explain "vicarious liability derives solely from the principal's legal relation to the wrongdoer, settlement with the tortfeasor removes the basis for any additional recovery from the principal upon the same acts of negligence." Id. A "single share" theory for liability results in the treatment of both agent and principal as one. Thus, a "settlement with an agent effectively adjudicates and satisfies the vicarious claim." Id. Therefore, the plaintiff cannot recover against the principal once recovery against the agent has been completed. The Iowa court also subscribes to the notion than an inapposite outcome would result in circuity of action and multiplicity of lawsuits. The court concluded: "such an outcome would clearly advance the goal of voluntary settlement of controversies favored by law. This is because of the well settled rule that a principal found vicariously liable for the negligent acts of an agent retains a right of full indemnity against the actual tortfeasor. The potential enforcement of such right... would clearly have discouraged rather than encouraged settlement." (Biddle, 518 N.W.2d at 798-799.)