On Nov. 15, 2008, at approximately 11 a.m., plaintiff Samantha Gilworth, 3, was strapped in a baby seat in a vehicle traveling on State Route 58 in Hinkley and operated by her grandmother, Ruth Gilworth. As the vehicle slowed down to make a left turn onto Hidden River Road, it was rear-ended by a pickup truck traveling 60 mph and operated by Rodney Most. Samantha suffered head . Samantha’s aunt, Wanda Mello, acting as the child’s guardian ad litem, sued the State of California Department of Transportation (Caltrans). Mello alleged that Caltrans failed to properly maintain the intersection, creating a dangerous condition of public property. Caltrans brought a third-party claim against Most, alleging that Most was negligent in the operation of the pickup truck. Mello subsequently added Most as a direct defendant, but then settled, on Samantha’s behalf, with Most for his insurance policy limits. Thus, the matter proceeded to trial against Caltrans only. Plaintiff’s counsel contended there was a road defect on SR-58 in the area of the subject accident. Counsel argued that Caltrans failed to provide a left-turn lane, or pocket, and that this caused the rear-end collision when Samantha’s grandmother attempted to make a left turn onto Hidden River Road. Thus, plaintiff’s counsel argued that the existence of a left turn area would have prevented the collision. Caltrans claimed that there was no defect in the specific area of SR-58 and that the roadway was safe when used with reasonable care. It also claimed the area in question did not meet the criteria for a left turn lane, or pocket, and that the accident was caused strictly by the negligence of the drivers involved., Samantha sustained fractures to her skull and a traumatic brain injury to the frontal lobes. She was subsequently taken by ambulance from the scene of the accident and brought to an emergency room. Samantha ultimately underwent a craniotomy and remained hospitalized for one month. Plaintiff’s counsel contended that Samantha suffers from cognitive deficits involving retention, memory, concentration, and ability to read and write. As a result, she is in special education classes at school and is very dependent in several aspects of her everyday life. Thus, plaintiff’s counsel asked the jury to award Samantha roughly $20 million in total damages, which included damages for Samantha’s pain and suffering, and $6 million in economic damages that consisted of Samantha’s future life care plan (assisted living) and loss of future earning capacity. Defense counsel conceded that Samantha suffered a traumatic brain injury, but argued that Samantha will eventually be able to work in some capacity and live independently with some assistance. Prior to the verdict, and mid-way through the trial, the parties established a $3 million/$1 million high-low agreement.