On Jan. 9, 2013, plaintiff Camille Carter, 67, a retired nurse who lived in Santa Barbara part-time, was walking south on De La Vina Street, toward a beauty salon she frequented, when she tripped and fell on a cracked and unleveled piece of sidewalk at or near 1922 De La Vina Street. As a result, Carter suffered a head injury. Carter sued the maintainer of the sidewalk, the city of Santa Barbara, and the owner of the adjacent property, 1922 De La Vina. Carter alleged that the deteriorated sidewalk constituted a dangerous condition of public property within the meaning of Government Code § 835. Thus, she alleged that the city and 1922 De La Vina failed to repair the dangerous condition. Carter claimed that at the time of her fall, the weather was warm, clear and dry, and the height differential of the sidewalk where she tripped was less than three quarters of an inch (although experts disagreed on the precise measurement). She also claimed that there were no visual obstructions to the sidewalk and that she had a general familiarity with the area, as she would regularly walk on that stretch of sidewalk to visit her beauty salon. Carter’s counsel contended that the city had constructive notice of the sidewalk’s dangerous condition due to the size and allegedly longstanding nature of the defect. Counsel also contended that since the city had performed a number of street repairs in the vicinity of the defect, it knew or should have known about the subject defect. Defense counsel argued that at the time of Carter’s fall, the sidewalk’s defect was trivial and did not constitute a dangerous condition of public property. The city denied it had notice of any prior claims or accidents at the location of Carter’s fall. It also noted that there were no records of prior accidents or repairs at the location of the incident. 1922 De La Vina contended that the missing piece of concrete was on the city’s sidewalk and that it did nothing to cause the sidewalk to deteriorate., Carter sustained a closed head injury and was subsequently taken by her husband to a hospital. She ultimately required two separate hospitalizations and a “burr hole” surgery to her head to relieve an intracranial hemorrhage. Carter claimed that she continues to suffer from memory difficulty, sleep problems, and anxiety. She also claimed that she continues to be unsteady, requiring the permanent use of a cane. Plaintiff’s counsel presented more than $150,000 in medical bills, with more than $35,000 of past medical bills submitted to the jury as paid. Thus, Carter sought recovery of medical costs, and of damages for her past and future pain and suffering.