On July 10, 2016, plaintiff Catherine Williams, 43, a college dean of administration, was bicycling on a county road near Sebastopol when she hit a pothole and crashed. Williams claimed to her head, face, hands, body and legs. Williams sued the maintainer of the roadway, Sonoma County, and four of the county’s management employees, Susan Klassen, John R. McCarthy, Rob Houweling and Nathan Mayo. The employees were dismissed from the case, and the matter continued against the county. Williams claimed that a local citizen had reported the pothole to the county 56 days before the accident and that claims were also reported by other citizens. She claimed that because the county had notice of the dangerous condition of public property, it was negligent for allowing it to remain for an unreasonable amount of time without repair. The defense’s accident reconstruction expert opined that Williams crashed due to over-braking. Defense counsel contended that the county had many other tasks with limited resources, and presented an affirmative defense under Government Code § 835.4, arguing that the county was not legally responsible for harm caused by the pothole if an act or omission of its employee who may have created the dangerous condition was reasonable. Counsel also contended that Williams was bicycling at approximately 25 mph and that the pothole was covered by shade at the time of the crash. Counsel argued that based on Williams’ speed and the conditions at the time, Williams was negligence per se under Vehicle Code § 22350, which states, “No person shall drive a vehicle upon a highway at a speed greater than is reasonable or prudent having due regard for weather, visibility, the traffic on, and the surface and width of, the highway, and in no event at a speed which endangers the safety of persons or property.” In addition, defense counsel asserted that Williams assumed the risk of her and that the county had governmental immunity. Based on motions for summary judgment, the court determined that no immunity applied. In addition, the assumption of the risk defense was defeated in motion. However, the court instructed the jury on the defense claims of reasonableness and negligence per se., Williams sustained a mandibular fracture and a complicated, mild traumatic brain injury with residual blood deposit. She also sustained torn ligaments in her hand, soft tissue to her neck and back, and multiple bruises and abrasions. In addition, she lost two teeth and had significant loss of mass to the upper jaw bone. Williams was taken by ambulance to the Santa Rosa Memorial Hospital’s Regional Trauma Center, in Santa Rosa, where she was hospitalized three days. Plaintiff’s counsel noted that while Williams’ brain CT was negative, her brain MRI finding was consistent with a shear injury in the brain stem. Williams saw a neurosurgeon, a psychotherapist, and many different neurologists and alternative care providers to treat her brain injury over the two years since the accident. She also underwent internal fixation of her jaw and three bone graft surgeries with an oral surgeon, but the bone grafts failed. In addition, Williams was evaluated by two prosthodontists and another specialist regarding future dental treatment and restoration/bridges, as Williams claimed that she will need significant, further dental restoration. Williams claimed that she is left with facial scarring and addition residual scarring as a result of the multiple bruises and abrasions. She also claimed that she now easily fatigued, sensitive to light and sound, has headaches, and suffers from disequilibrium. Williams further claimed that she is permanently impaired, affecting her cognitive function and memory, and that there is a probability of deterioration. However, Williams was able to return to work almost three months after the accident. The plaintiff’s expert neuropsychologist opined that, based on Williams’ continued problems at work as a dean of instruction and enrollment at Santa Rosa Junior College, and Williams’ continued cognitive and memory problems, Williams’ brain injury is permanent. The expert also opined that Williams will need further psychological counseling and neuropsychological evaluations. In addition, the expert opined that Williams is susceptible to further concussions or brain trauma as a result of her . The defense’s expert neuropsychologist opined that Williams had no impairment by the time of his evaluation in August 2018 and that most people with mild traumatic brain injury recover in about three months, but that it varies. The expert also testified that Williams performed in the superior range on most cognitive functioning assessments. As a result, the defense expert opined that Williams had fully recovered from his .