In Biddle v. Sartori Memorial Hospital, 518 N.W.2d 795 (Iowa 1994), an emergency patient was negligently discharged from the hospital by her physician. Her legal representative released the physician from liability after a settlement had been reached with the physician. The hospital was thereafter sued for the physician's negligence on a vicarious liability claim. The Iowa Supreme Court acknowledged the "fundamental distinction between the full recovery permitted under the doctrine of joint and several liability, and the limitations inherent in a claim that rests on the doctrine of vicarious liability." Id. at 798. The Biddle court emphasized the need to address "head-on this important distinction." Id. The Biddle court discussed opinions of other jurisdictions holding that settlement with the tortfeasor removes the basis for any additional recovery from the principal upon the same acts of negligence. The Biddle court adopted the theory that the agent and the principal should be treated as one, applying the single share theory for liability to permit a "settlement with an agent to effectively adjudicate and satisfy the vicarious claim." Id. An opposite outcome, the Biddle court reasoned, would generate multiplicity of civil actions and a circuity of claims. The court noted that the doctor's settlement would not be protected if a cause of action were permitted to go forward against the hospital. 518 N.W.2d at 799. "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 for enforcement of such a right. . . would clearly have discouraged rather than encouraged settlement. . . ." Id. at 799.