On Feb. 8, 2011, at approximately 5 p.m., plaintiff Sapreena Fowler, 18, a patient in a mental health facility, was sitting on the floor of a hallway surrounded by staff of Redwood Place, a locked, inpatient mental health rehabilitation center for the developmentally disabled and mentally ill, located in Castro Valley. Sapreena was severely disabled, with the intellectual and social development of a four-year-old, and conserved by the state. Alameda County Sheriff’s Deputies Rosario Robson and Misty Johnson were dispatched to Redwood Place to check on another resident. However, when they arrived at the rehabilitation center, they saw Sapreena sitting on the floor of the hallway, crying hysterically, with staff members allegedly using their professional assault crisis training to calm her down. When it appeared that staff members were not able to control the patient, Robson and Johnson restrained and handcuffed Sapreena, who was then transported for medical and mental assessment. She subsequently spent one night at John George Psychiatric Pavilion in San Lorenzo, and then two nights at the psychiatric unit of Santa Rita Jail in Calif., where she was charged with felony assault of a police officer. Sapreena, by and through her guardian ad litem, Holly Webb, sued Robson and Johnson, as well as their employers, the county of Alameda and the Alameda County Sheriff’s Office. Sapreena also sued Deputy Micah Bennett, who charged Fowler with a felony, requiring her to obtain criminal counsel to get the case against her dismissed. She alleged that the actions of Robson and Johnson constituted gross excessive force; a violation of her constitutional rights with threats, intimidation, and/or coercion; and assault and battery. She also alleged that all of the defendants’ actions constituted false arrest and imprisonment, malicious prosecution and negligence. Sapreena’s counsel contended that while the staff of Redwood Place was five minutes into using their professional assault crisis training, Robson and Johnson, misinterpreting the situation and without asking whether the staff needed help, pounced on Sapreena and pushed her face down to the ground while screaming at her. Counsel contended that the deputies then punched Sapreena in the face and body, pulled her hair, kneed her, kneeled on her, and jammed an elbow in her back before handcuffing her. In addition, counsel contended that the deputies used a Taser on Sapreena’s back twice. Plaintiff’s counsel further contended that while Sapreena was crying on her stomach after being handcuffed, Sapreena’s caregiver went on the ground to be face to face with her in an attempt to try to calm her down. Counsel contended that the caregiver then told Sapreena that she was safe and that she was going to be taken to John George Psychiatric Pavilion and then back to Redwood Place. However, counsel claimed that in response to the caregiver, one of the deputies yelled, “I’m not taking this b-tch to John George; I’m taking her to jail!” Sapreena remained in custody for three nights. Robson and Johnson claimed that when they arrived at Redwood Place, they saw Sapreena striking out at the staff, and that staff members were not able to control the patient with verbal statements to cease her violent behavior. They claimed that Redwood Place staff then deferred to them, and did not offer any verbal caution or instruction to help assist them in controlling the situation. However, the deputies claimed that when they attempted to intervene, Sapreena spit on them, thereby assaulting them. They further claimed that despite her mental impairments, Sapreena was a large, young woman without any physical disability, and that she had a history of uncontrolled, physical rages that threatened injury to the staff, other patients and herself., Sapreena claimed she suffered some bruising as a result of being struck in the face and body, as well as being shocked with a Taser, but that her main injury was the severe emotional distress she suffered as a result of the incident. She alleged that her emotional distress lasted for some months, but that she did not incur permanent from the incident. Thus, Sapreena sought recovery of damages for her emotional distress. She also sought injunctive relief to govern the deputies’ presence in Redwood Place in the future and to remind them of their law enforcement training, in that when dealing with mentally ill or developmentally disabled persons they should speak quietly, assume a non-threatening manner, and give the person time to calm down. Defense counsel contended that Sapreena incurred no damages from the incident. Counsel noted that the subpoenaed medical and psychiatric records documented that Sapreena did not sustain any injury other than minor bruising from the handcuffs.