BATTAGLIA, J.

We are asked to consider whether, in a medical malpractice action, a judgment entered after a jury trial against a negligent tort-feasor,1 already reduced by a settlement entered into with a hospital corporation, with an attendant release, may be further diminished by requesting a "judicial determination" of negligence against three employees of the hospital, who were never joined as parties in the action. In so doing, we are faced with the following questions on certiorari, Hashmi v. Bennett, 412 Md. 494, 988 A.2d 1008 (2010), which we have renumbered:

We shall hold that the release of the hospital clearly and unambiguously encompasses all of its employees and agents; we shall further hold that a "judicial determination" of joint tort-feasor status of employees of the releasing hospital after the conclusion of all proceedings in the case, when they were never joined as defendants or cross-defendants, is impermissible.

On September 8, 2005, Troy Bennett, Geraldine Bennett, Keion Bennett, Tyshaun Bennett, and Adam Gross, Respondents, (hereinafter "the Bennetts") filed a survival and wrongful death action in the Circuit Court for Baltimore City against Emergency Physician Associates of Maryland, P.C., Shoaib A. Hashmi, M.D., and The Good Samaritan Hospital of Maryland, Inc., in connection with the death of twenty-seven year old Adrian Tyree Bennett from septic shock. Subsequently, on November 16, 2005, by a First Amended Complaint and Election for Jury Trial, Respondents joined Roman Kostrubiak, M.D. as a defendant.

The Bennetts asserted that the health care providers failed to diagnose and appropriately treat Adrian's methicillin-resistant staphylococcus aureus infection,2 alleging the following:

The Bennetts alleged that Dr. Kostrubiak negligently misdiagnosed and mistreated Adrian's infection:

The Bennetts further alleged that Dr. Hashmi breached applicable standards of care:

Finally, the Bennetts alleged that Good Samaritan Hospital failed to timely diagnose and adequately treat Adrian's infection and sepsis:

Dr. Kostrubiak along with Emergency Physician Associates of Maryland answered, as did Good Samaritan Hospital, generally denying liability, and asserting affirmative defenses including contributory negligence and assumption of risk. Dr. Hashmi also answered, generally denying liability and asserting contributory negligence and assumption of risk as affirmative defenses.

On October 10, 2006, the complaints against Dr. Kostrubiak and Emergency Physician Associates of Maryland, as well as Good Samaritan Hospital, were dismissed with prejudice as a result of separate settlements,3 in accordance with Rule 2-506(a).4 The Bennetts executed a "Joint Tortfeasor Release," discharging all claims against Emergency Physician Associates of Maryland and its employee, Dr. Kostrubiak, in exchange for $400,000.5

The Good Samaritan "Settlement Agreement and Release,"6 at issue in the present case, provided, in relevant part:

Dr. Hashmi, however, did not settle, nor did he file any third-party claim alleging that another party's negligence contributed to Adrian's death.7 During the one-week trial that ensued regarding the claims against him, moreover, Dr. Hashmi did not implicate any other Good Samaritan Hospital employee or any one else as responsible for Adrian's allegedly deficient care and subsequent death. The jury returned a verdict in favor of the Bennetts, and the verdict sheet provided as follows, regarding Dr. Hashmi's liability:

Judgment was entered on the verdict against Dr. Hashmi in the amount of $2,295,000, although he, thereafter, filed a "Motion for Remittitur or to Reduce the Verdict," asserting that the total verdict exceeded the statutory cap on noneconomic damages established in Section 11-108 of the Courts and Judicial Proceedings Article, Maryland Code (1973, 2006 Repl. Vol.).8 He also filed a "Supplemental Memorandum in Support of Motion to Reduce Verdict," claiming entitlement to an additional reduction, pursuant to the Maryland Contribution Among Joint Tort-Feasors Act.9 In this regard, he asserted that he was entitled to contribution under the Act, not only from Emergency Physician Associates of Maryland and Dr. Kostrubiak, as well as Good Samaritan Hospital, but also from "[t]hree distinct actors employed by Good Samaritan Hospital," namely (1) Dr. Hina Sahi, a hospital resident;10 (2) Nurse Kathleen Bosse, a hospital floor nurse;11 and (3) an unidentified emergency room nurse, Nurse A.12

The Bennetts resisted the reduction by three more "shares"13 by countering that the alleged joint tort-feasors, Dr. Sahi, Nurse Bosse, and Nurse A, "were never named as defendants, never admitted liability to Plaintiffs, and never were found liable to Plaintiffs by a court or jury" and posited that the clear and unambiguous language of the Good Samaritan Release contemplated only one joint tort-feasor.

After a hearing, Judge Kaye A. Allison reduced the judgment to $1,795,000, pursuant to the statutory cap on noneconomic damages set forth in Section 11-108 of the Courts and Judicial Proceedings Article. With respect to the issue of increasing the contribution Dr. Hashmi was to receive from the three alleged joint tort-feasors, Judge Allison determined that the $1.7 million verdict would be divided among Emergency Physician Associates along with Dr. Kostrubiak, Good Samaritan Hospital, as well as Dr. Hashmi, for three shares rather than five shares, calculated on the basis of the three Good Samaritan employees, Dr. Kostrubiak along with Emergency Physician Associates, and Dr. Hashmi. Accordingly, judgment was entered against Dr. Hashmi in the amount of $598,333.33, representing his one-third joint tort-feasor share.

Dr. Hashmi appealed to the Court of Special Appeals, and our colleagues on the intermediate appellate court affirmed in a reported opinion, Hashmi v. Bennett, 188 Md.App. 434, 982 A.2d 818 (2009), reasoning that the language of the Good Samaritan Release clearly and unambiguously identified Good Samaritan Hospital as the joint tort-feasor and that "Dr. Sahi, Nurse Bosse, and Nurse A, as non-parties to the settlement agreement, could not attain joint tortfeasor status." Id. at 451, 982 A.2d at 828.

Discussion

When multiple tort-feasors cause harm to an injured party, the issue arises as to whether one of them may be held liable for all of the negligence, or whether each tort-feasor may individually be held responsible in a proportionate or equal manner for the injury. The right of contribution among negligent joint tort-feasors was not recognized at common law, so that a single tort-feasor could bear the entirety of the loss sustained by the injured party. 1 Stuart M. Speiser, Charles F. Krause, & Alfred W. Gans, The American Law of Torts § 3:15 (2003); see also William L. Prosser, Law of Torts 305-07 (4th ed.1971). The right of "contribution," in contrast, enables a tort-feasor "to collect from joint tortfeasors when — and to the extent that — the tortfeasor has paid more than his or her proportionate share to the injured party." Black's Law Dictionary 378 (9th ed.2009).

The common law rule endured criticism for foisting the entire obligation on one tort-feasor, rather than "achieving equal or proportionate distribution of the common burden," and was abrogated in many states, including Maryland, by the enactment of the Uniform Contribution Among Tortfeasors Act, promulgated by the National Conference of Commissioners on Uniform State Laws in 1939. Unif. Contribution Among Joint Tortfeasors Act, Prefatory Note, 12 U.L.A. 196 (2008). The Act was developed to promote "some common policy" to legislatively establish contribution among joint tort-feasors. Id.

Section 3-1401 of the Act defines "joint tort-feasors" as follows:

Section 3-1402 codifies the right of contribution among joint tort-feasors, providing:

Section 3-1403 abrogates the prior rule, in which the recovery of a judgment against one joint tort-feasor discharged any other joint tort-feasors:

Section 3-1404 describes the effect of a release on nonsettling joint tort-feasors, namely reducing the claim either "in the amount of the consideration paid" or the "proportion by which the release provides":

Section 3-1405 states that a release of one joint tort-feasor may extinguish the right of contribution, so long as the release provides for a reduction in any recovery by the injured party of the pro rata share of the released tort-feasor:

In the context of these contribution statutory provisions, Dr. Hashmi, not a party to the Good Samaritan Release, claims that the Release language is ambiguous, because it refers to multiple hospital employees and agents in defining "Released Party" or "Releasee." As a result, Dr. Hashmi contends that the Release actually refers to three distinct joint tort-feasors, namely Dr. Sahi, Nurse Bosse, and Nurse A. The Bennetts, who were parties to the Release, counter that the Release unambiguously refers to Good Samaritan Hospital as "a Joint Tortfeasor" and that Dr. Hashmi "never proved (or even attempted to prove) ... that any specific Good Samaritan agents were separate individual joint tortfeasors, i.e. were negligent and caused Mr. Bennett's death."

In construing the Good Samaritan Release, we resort to principles of contract interpretation. Owens-Illinois, Inc. v. Cook, 386 Md. 468, 496, 872 A.2d 969, 985 (2005). The principle of the objective interpretation of contracts governs, Clancy v. King, 405 Md. 541, 557, 954 A.2d 1092, 1101 (2008), quoting Cochran v. Norkunas, 398 Md. 1, 16, 919 A.2d 700, 710 (2007), so that if a release is clear and unambiguous, "there is no room for construction, and a court must presume that the parties meant what they expressed." Cook, 386 Md. at 496, 872 A.2d at 985 (citation omitted). "Under the objective law of contract interpretation, the court will give force and effect to the words of the contract without regard to what the parties to the contract thought it meant or what they intended it to mean." Langston v. Langston, 366 Md. 490, 507, 784 A.2d 1086, 1095 (2001). Our task when interpreting a contract is to "[d]etermine from the language of the agreement itself what a reasonable person in the position of the parties would have meant at the time it was effectuated." Calomiris v. Woods, 353 Md. 425, 436, 727 A.2d 358, 363 (1999) (citation omitted).

Dr. Hashmi emphasizes that the definition of "Released Party" or "Releasee" in Section I encompasses all hospital employees and agents, with the exception of himself, as follows:

As a result, he contends, the Release language is ambiguous regarding whether a single joint tort-feasor share or multiple shares for Dr. Sahi, Nurse Bosse, and Nurse A are included.

In contrast, the Bennetts highlight the language of Section IV of the Release, which identifies Good Samaritan Hospital as "a Joint Tortfeasor," as follows:

It is true that Section I defines "Released Party" or "Releasee" globally, releasing all employees and agents of Good Samaritan Hospital, with the exception of Dr. Hashmi. Section IV, however, identifies Good Samaritan Hospital, the "Released Party" as "a Joint Tortfeasor," such that the Release both broadly encompasses hospital employees and agents, while nevertheless representing one joint tort-feasor share.

Our interpretation comports with that of our colleagues on the intermediate appellate court, who determined that the Release clearly and unambiguously identifies Good Samaritan Hospital only as "a joint tort-feasor." As the Court of Special Appeals aptly noted, "an agreement could only determine joint tort-feasor status of one who was a party thereto," 188 Md. App. at 451, 982 A.2d at 828, quoting Jacobs v. Flynn, 131 Md.App. 342, 371, 749 A.2d 174, 189 (2000), and only the Bennetts and Good Samaritan Hospital were parties to the Release. Thus, we decline to embrace Dr. Hashmi's tortured analysis, as the Release contains no admission or other statement that Dr. Sahi, Nurse Bosse, or Nurse A are deemed to be joint tort-feasors.14

Even if we were to determine that the Good Samaritan Release was ambiguous, we would not countenance the separate, post-trial proceeding Dr. Hashmi proposes, in which he suggests that the proffer of evidence in a separate post-judgment judicial proceeding against Dr. Sahi, Nurse Bosse, and Nurse A, who are not parties to the action, would be sufficient to establish their status as joint tort-feasors in order to reduce his contribution to the adjudicated verdict.15 None of the three Good Samaritan employees was named as a defendant in the original action, nor did Dr. Hashmi join them as third-party defendants pursuant to Rule 2-332(a), which provides:

Rather than pursue a "judicial determination" countenanced by our Rules, Dr. Hashmi, in an effort to increase the number of joint tort-feasor shares, thereby reducing his share of the judgment, seeks to demonstrate that Dr. Sahi, Nurse Bosse, and Nurse A were also negligent in a collateral, post-judgment proceeding, without Dr. Sahi, Nurse Bosse and Nurse A being notified or even necessarily being present or defending.16

Never has this Court, or as far as we can tell, any other court, permitted this type of "judicial determination" of joint tort-feasor status, without their having been joined as original defendants or as third parties.17 Rather, in Owens-Illinois, Inc. v. Zenobia, 325 Md. 420, 601 A.2d 633 (1992), we determined that only a party to an action may be deemed a "joint tort-feasor." In that case, Louis L. Dickerson and William L. Zenobia filed separate complaints seeking damages for injuries resulting from asbestos exposure against a number of manufacturers and installers of products containing asbestos, and the complaints were consolidated for purposes of trial and appeal. A jury awarded Mr. Dickerson $1.3 million in compensatory damages and Mr. Zenobia $1.2 million in compensatory damages. Pursuant to a stipulation, each defendant was deemed to have cross-claimed for contribution and indemnity against all other defendants. Raymark, Inc., an asbestos manufacturer, however, was not a party to the Zenobia case or the cross-claim stipulation in Zenobia, and had settled with Mr. Dickerson and Mr. Zenobia before trial. Anchor Packing Co., a defendant in the Zenobia case, sought indemnity from Raymark, asserting that Raymark was Anchor's primary source of asbestos containing products.

The trial judge granted defendants' cross-claims against all settling defendants, including Raymark, in the Dickerson and Zenobia cases. As a result, the compensatory damages verdicts were reduced proportionally in light of the releases between the plaintiffs and the settling defendants. In addition, the trial judge held that Anchor Packing was entitled to indemnity against Raymark in the Zenobia case. Thus, because of Mr. Zenobia's settlement and release of Raymark, the trial judge struck the jury's award against Anchor.

We reversed with respect to both claims. Regarding the Dickerson case, we reasoned that, because Raymark was named as a defendant in Mr. Dickerson's original complaint, the cross-claim stipulation included cross-claims against Raymark for contribution. We determined, nevertheless, that the trial judge erred, "because there was insufficient evidence to find that Raymark was a joint tort-feasor." Id. at 475, 601 A.2d at 660. We emphasized that "[n]o evidence was presented against Raymark at the trial," such that the nonsettling defendants had not met their burden of demonstrating Raymark's joint tort-feasor status. Id.

We further held, in the Zenobia case, that, because Raymark was never named as a defendant, or impleaded as a third-party defendant pursuant to Rule 2-322, "[t]he trial court could not exercise jurisdiction to grant a cross-claim against Raymark." Id. at 474, 601 A.2d at 660. In so holding, we noted that Raymark was deprived of notice in contradiction with Rule 2-322 requiring service, upon a person not previously a party to the action, of a summons, the complaint, and all pleadings and motions previously filed in the action.

Here, as in the Dickerson case, Dr. Hashmi failed to present any evidence at trial against the three Good Samaritan Hospital employees. Moreover, as in the Zenobia case, Dr. Sahi, Nurse Bosse, and Nurse A were never named as defendants or impleaded by Dr. Hashmi as third-party defendants pursuant to Rule 2-322. As a result, our precedent does not comport with Dr. Hashmi's last-ditch effort to reduce his share of the judgment by seeking an adjudication of joint tort-feasor status of Dr. Sahi, Nurse Bosse, and Nurse A, who have not received notice or had an opportunity to defend. See also Porter Hayden Co. v. Bullinger, 350 Md. 452, 471-72, 713 A.2d 962, 971 (1998) (reasoning that a default judgment entered on an asbestos manufacturer's third-party claim against a third-party defendant constituted a determination of liability, such that the third-party defendant should be considered a joint tort-feasor under the Act); Lerman v. Heeman, 347 Md. 439, 446, 701 A.2d 426, 430 (1997) (determining that a jury verdict had pronounced Dr. Lerman and Dr. Heeman, defendants in a medical malpractice action, to be "joint tort-feasors," such that Dr. Heeman could seek contribution from his co-defendant, because he had paid more than his pro rata share of the judgment); Owens-Corning Fiberglas Corp. v. Garrett, 343 Md. 500, 532, 682 A.2d 1143, 1159 (1996) (concluding that a manufacturer of asbestos-containing products could not seek contribution from settling cross-defendants who were determined by the trier of fact not to be "liable in tort"); Keene Corp. v. Levin, 330 Md. 287, 293-94, 623 A.2d 662, 665 (1993) (reasoning that a final judgment may not be entered until cross-claim liability was determined, because if a cross-defendant is liable as a joint tort-feasor, there is a right of contribution which may reduce the amount of judgment); Allgood v. Mueller, 307 Md. 350, 355, 513 A.2d 915, 918 (1986) (determining that settling co-defendants who remained in case and were found not to be liable were volunteers regarding their payments to plaintiffs, and nonsettling defendant who was found liable was not entitled to a reduction of the judgment awarded against it); Swigert v. Welk, 213 Md. 613, 621-22, 133 A.2d 428, 432-33 (1957) (granting summary judgment in favor of settling third-party defendant was inappropriate, because the question of his negligence had yet to be determined); Collier v. Eagle-Picher Industries, Inc., 86 Md.App. 38, 43-44, 585 A.2d 256, 259 (1991) (recognizing in an asbestos claim a general pre-trial order in which each of the defendants was deemed to have filed cross-claims for contribution against all other defendants); Loh v. Safeway Stores, Inc., 47 Md.App. 110, 127, 422 A.2d 16, 26 (1980) (determining summary judgment in favor of grocery store and food producer was improper, despite settlement by injured party with food producer, because the producer specifically denied liability and thus, "there ha[d] been no determination of liability").

In so holding, we also find persuasive Washington v. Washington Hospital Center, 579 A.2d 177 (D.C.1990), in which the District of Columbia Court of Appeals was faced with an analogous scenario. In that case, a jury returned a verdict against Washington Hospital Center in connection with the improper administration of anesthesia, causing a patient to sustain severe brain damage. Id. at 180. Washington Hospital Center sought a reduction of the verdict, asserting that the other two alleged tort-feasors, the anesthesiologist, Dr. Walker, and the nurse-anesthetist, Nurse Adland, executed settlement agreements with the patient. Id. at 185. The court determined that the Hospital's "failure to keep that issue in the case by asserting a claim for contribution—either through a cross-claim or by a special jury verdict request—preclude[d] application of a pro rata credit." Id. at 186. The court emphasized that the Hospital could reasonably have been expected to "`safeguard any legitimate claim it might have to lessen the burden of a plaintiff's verdict' by asserting a cross-claim for contribution ... or an equivalent request for a determination by the jury of the settling defendants' negligence." Id. at 187-88, quoting Hall v. General Motors Corp., 647 F.2d 175, 184 (1980). Although the District of Columbia has not adopted the Uniform Contribution Among Joint Tort-Feasors Act and relies instead on contribution as an equitable remedy, George Washington University v. Bier, 946 A.2d 372, 375 (D.C.2008), we nevertheless find appropriate the notion that only a party to the action may be deemed a "joint tort-feasor." See Owens-Illinois, Inc. v. Zenobia, 325 Md. 420, 473-75, 601 A.2d 633, 659-660 (1992).

In this case, Dr. Hashmi could have pursued a claim against any other alleged joint tort-feasors, other than those named in the original complaint, by filing a third-party complaint pursuant to Rule 2-332 and by seeking a special verdict, rather than by asserting the efficacy of a post hoc proceeding in which only he would proffer. Obviously, such a chimera will not be countenanced.

JUDGMENT OF THE COURT OF SPECIAL APPEALS AFFIRMED. COSTS IN THIS COURT AND IN THE COURT OF SPECIAL APPEALS TO BE PAID BY PETITIONERS.