On June 11, 2014, plaintiff Shiow-Huey Chang, 40, a Chinese-American registered nurse, was driving her maroon Lexus sport utility vehicle on the Foothill Expressway, near Cupertino, when she was stopped by Santa Clara County Sheriff’s Deputy Daniel Forest, who cited her for “impeding traffic.” Chang declined to sign the ticket until she could speak to Forest’s supervisor. She was ultimately pulled out of her car and arrested for assaulting a peace officer. Deputy Rachel Strickland assisted Forest in making the arrest. The Santa Clara County District Attorney charged Chang only with resisting arrest and subsequently dismissed the charge “for insufficient evidence and in the interest of justice.” Chang sued Forest; Strickland; and the deputies’ employers, the county of Santa Clara and the Santa Clara County Sheriff’s Office. Chang alleged that the defendants’ actions constituted excessive force in violation of her rights under the Fourth Amendment. Plaintiff’s counsel noted that the encounter was recorded on the dashboard camera of Forest’s patrol vehicle and on Strickland’s lapel microphone. According to plaintiff’s counsel, the video showed that Forest pulled up next to Chang and yelled, “Why are you f—ing stopping?” Chang claimed that she told the deputy that she was slowing down in order to let Forest pass her, but that she could not pull over due to two cyclists in the bike lane. She claimed that as a result, Forest attempted to give her a ticket for “impeding traffic,” but that when she declined to sign the ticket until she could speak to his supervisor, she was pulled out of her car by her arm, slammed against the side of the vehicle, and arrested for assaulting a peace officer. Thus, she claimed Forest violated her constitutional rights by using excessive force against her. Plaintiff’s counsel noted that after the incident, Chang made an Internal Affairs complaint, but the sheriff’s office exonerated the two deputies and sent a letter from Sheriff Laurie Smith stating that the conduct of Forest and Strickland was lawful, proper, and justified. However, plaintiff’s counsel argued that Internal Affairs had not interviewed either deputy, had not requested the deputies’ statements, and, in fact, had not even talked to them. Due to this, Chang made a Monell claim against the county. According to plaintiff’s counsel, Chang had attempted to claim that Forest had violated the constitutional rights of another Chinese-American female professional eight years earlier, but the court excluded evidence of the alleged incident by granting defense’s counsel motion. Defense counsel contended that the video clearly showed Chang reaching out of her vehicle and striking the deputy’s ticket book and that Chang even admitted that she struck Forest’s finger during the incident. Thus, counsel argued that Chang’s action of hitting the deputy’s ticket book constituted an assault. Defense counsel further argued that Chang would not have stepped out of her vehicle and submit to an arrest, if asked, so the deputies used a reasonable amount of force to get Chang out of her vehicle., During the course of the arrest, Chang’s glasses were broken, her cheek was cut, and she was bruised in numerous places. She also claimed a small laceration under her left eye, wrist pains, and bruising. She subsequently underwent minimal medical treatment at an emergency room and she claimed she had no residual . Thus, Chang mainly sought recovery of over $37,000 in legal fees in connection with the defense of her criminal matter, She also sought recovery of other miscellaneous expenses, including vehicle impound fees, and the costs to repair or replace her broken eyeglasses.