On Sept. 24, 2013, plaintiff’s decedent Connor Zion, 21, a ballroom dancer, experienced a mental health crisis following a series of seizures. Zion suffered nocturnal epilepsy and other psychological and mental health disabilities. While in crisis, he struggled with his roommate and injured the roommate with a kitchen knife. Zion’s mother cut her hand as she took the kitchen knife from Zion, and neighbors called 911 to get medical attention for Zion and his roommate. Orange County sheriff’s deputies responded to the scene. Deputy Juan Lopez arrived first. As he exited his patrol car, Zion ran toward him with a knife. A foot chase ensued, resulting in a physical struggle between Lopez and Zion wherein Lopez suffered knife wounds to his arms. Deputy Michael Higgins, who pulled up in his patrol car right after Lopez, jumped back into his car and backed up upon seeing Zion run toward Lopez. Higgins jumped out of his car, drew his gun and fired several shots at Zion, who eventually collapsed on a walkway. Zion suffered 15 gunshot wounds and died at the scene. The entire encounter and use of force was captured on dash-cam video from the deputies’ patrol vehicles. The decedent’s mother, Kimberly Zion, acting individually and as her son’s successor in interest, sued Higgins and Higgins’ employer, Orange County. Ms. Zion alleged that Higgins was negligent in the use of excessive force, causing her son’s wrongful death, in violation of the Fourth Amendment, and that Higgins deprived her child of due process, in violation of the Fourteenth Amendment. She also alleged that the county was vicariously liable for Higgins’ actions while in the course and scope of his employment. Plaintiffs’ counsel contended that after Higgins backed up his patrol car, Higgins jumped out of his car, drew his gun and fired nine shots at Mr. Zion, who was running away from Lopez. Counsel also contended that six of those bullets hit Zion, who then collapsed on a walkway while a neighbor who was in the line of fire cowered nearby. Counsel further contended that as Zion was lying on the ground, unarmed, seriously injured and barely moving, Higgins stood over Zion’s body and fired nine more shots, emptying his gun at point-blank range. In addition, plaintiffs’ counsel contended that, before retreating to help Lopez, Higgins briefly walked away from Zion before turning back, breaking into a short run and stomping Zion’s head. Counsel contended that Higgins then stomped Zion’s head twice more, fracturing his skull in two places. Plaintiffs’ counsel argued that Higgins’ use of force regarding the second volley of nine shots and three blows to the head was excessive. Counsel also argued that Higgins’ actions caused Zion’s wrongful death and Zion’s loss of familial relations. Defense counsel maintained that the whole incident between Zion and the deputies occurred over 23 seconds and that Zion was killed by the first round of bullets. Counsel also argued that Higgins’ actions were justified, as Higgins feared for his life and that of Lopez. In addition, defense counsel noted that the Orange County District Attorney’s Office found that Higgins’ response was reasonable and justified, and that it declined to file criminal charges against Higgins., Connor Zion sustained 15 gunshot wounds and his skull was fractured in two places as a result of having his head stomped on. He ultimately died at the scene. Zion’s mother sought recovery of wrongful death damages for the loss of her son. She also sought recovery of damages for her son’s pre-death pain and suffering due to the excessive use of force in the second nine gunshots and three stomps to the head. In addition, she sought recovery of punitive damages against Higgins. Defense counsel denied there was any pre-death pain and suffering, arguing that Mr. Zion died from the first round of bullets.