In July 2014, plaintiff Robert Watts, 58, a camera company owner, was bicycling on Pacific Coast Highway, in Pacific Palisades. As he steered into the main road of travel to avoid debris on the shoulder, Watts was struck by a truck’s side mirror, lost control of his bicycle, and sustained to his head. Watts sued the maintainer of the highway, the city of Los Angeles, and the owner of the highway, the state of California, through the California Department of Transportation. Watts also brought a claim against the driver of the truck, Matthew Dymond, who agreed to settle with Watts. However, the city brought a cross-claim against Dymond, and a default judgment was entered against him. In addition, the state (Caltrans) settled out of the case prior to trial. Plaintiff’s counsel contended that sand and debris frequently roll down a cliff and onto the pavement, in an area known as the Tramonto slide, and that state and local officials were aware that the debris could create a dangerous condition along a route that was popular for bicyclists. Counsel also contended that since the dangerous condition had been known for years, Caltrans hired the city to sweep the pavement at least once a month to keep it free of debris. However, plaintiff’s counsel noted that two city street sweepers testified that they could not sweep at the bottom of the landslide. The city agreed that the bottom of the landslide blocked the shoulder of the road. However, the city’s counsel argued that the subject cliff was on state property and that the city could only sweep trash, as the street sweepers swept debris and could not sweep at the cliff., Watts sustained blunt force trauma to his head and was rendered unconscious. He was taken to a hospital, where it was determined that Watts had sustained significant brain damage to the frontal lobe and that he suffered from amnesia for 30 days. Watts claimed he suffers from brain damage, which left him with memory problems, sensitivity to light, no sense of smell, and hearing problems, which affects his ability to play guitar. He also claimed that he has permanent cognitive diminution, causing him to have stilted conversations. Watts alleged that he can no longer work as a result of his condition. Watts sought recovery of past and future medical costs, and damages for his past and future pain and suffering. The parties agreed that Watts has moderate to severe brain damage and that he suffered from past and future lost earnings.