At around 4:30 p.m. on June 27, 2014, plaintiffs’ decedent Juan Zabala, 32, was trying to obtain documents from the Alternative Action Program, where he was enrolled in a drug rehabilitation program. There was a disagreement about the documents, and security was called. Two security guards arrived, spoke to Zabala, and tried to persuade him to leave the offices of the program. When Zabala resisted, the security guards began to physically push him out. As a result, a scuffle ensued, during which Ventura police officers Robert Roldan and David McAlpine arrived. They assisted in the struggle with Zabala and were ultimately able to get Zabala outside, where they secured handcuffs on him behind his back. The officers then sat Zabala down on the curb while they examined his wallet. Zabala was initially calm, but he then stood up and ran westbound into an adjacent parking lot. Roldan, McAlpine and at least one other officer chased Zabala. When they caught up with him, one of the officers grabbed Zabala by the arm and back, and tackled him to the ground. Zabala fell on the west side of a vehicle parked in the lot. Due to his hands being handcuffed behind his back, he was unable to break the fall and violently struck the left side of his head against the asphalt. As a result, Zabala suffered various , including bruising, scrapes, and abrasions to his left cheek, arms, wrists, hands, torso, back, knees, and feet. Due to the sustained in the fall, Zabala was transported to the Ventura County Medical Center, in Ventura, at 5:19 p.m. He was examined by a nurse and a resident doctor, and an emergency room physician, and they collectively obtained a short history from Zabala, who indicated that the obvious contusion on the left side of the head was due to the police takedown. No history was obtained or offered by the officers. The emergency room doctor learned that Zabala had an addiction to methamphetamine, but that Zabala had last ingested meth the day before. Zabala’s cousin also confirmed that he took Zabala’s drugs away from him the day before. The emergency room physician did not observe any objective symptoms that Zabala was presently under the influence of methamphetamine and, after noting the lack of evidence of loss of consciousness, vomiting, headaches, or significant evidence of head trauma, he concluded that the injury to the head was not serious enough to warrant further examination or treatment. A a result, he gave the officers clearance to book Zabala in the county jail. Zabala was then transported to the Ventura County jail, where he arrived shortly before 9 p.m. At first, Zabala cooperated with the officers during the pre-booking process. However, after a few minutes, Zabala began to complain that he was feeling sick. As the Ventura County deputies began to interact with him, they noted a distinct behavioral problem, and asked Zabala if he had suffered a serious injury in the last 24 hours or had he seen a doctor for psychiatric reasons. Zabala then walked toward McAlpine, and the deputy pushed him up against a padded wall. As a result, Zabala attempted to kick the deputy by lifting his leg. Roldan then walked in and confronted Zabala, asking him what was wrong. Zabala said nothing was wrong, so Roldan asked him, “Then why are you kicking and fighting?” When Zabala continued to struggle, other deputies assisted in taking him to the ground. A nurse observed the incident, and Roldan told her, “We had to fight him in the field too.” Several other deputies then began to assist in controlling Zabala, while the nurse attempted to take his blood pressure. However, Zabala didn’t appear to understand. The deputies then collectively lifted his body and put him on a blanket for transport to a safety cell. He was heard grunting while being carried to the cell. The deputies then cut off his clothing, hobbled his feet, removed the handcuffs, and exited the cell. However, Zabala could still be observed thrashing about in the cell and rolling around for five hours (all caught on video). He could also be observed attempting to stand several times and falling to the ground, as if he was unbalanced. He also held his head with his hands and, at times, bumped his head against the wall. At approximately 2:37 a.m., Zabala fell backward and struck his head, causing a loud thud. A nurse heard the sound, immediately went to Zabala’s cell door, and called out to him, but he did not respond. Deputies then opened the cell door and entered it. Zabala was found unconscious and unresponsive. He was also not breathing and had no pulse. They subsequently called on the radio for “fire and ambulance” to respond Code 3 (lights and sirens), and chest compressions were initiated until fire personnel took over. CPR continued as paramedics arrived, and Zabala was placed in an ambulance for transport to Community Memorial Hospital, in Ventura, while he was in cardiac arrest. At the hospital, medical personnel were able to get Zabala breathing again, but a CT scan indicated that there was a cerebral edema and an impending herniation. The brain scan identified an intracranial hemorrhage and a marked brain edema with near total compression of the ventricular cisterns and loss of sulci. In addition, there was no evidence of neurological activity. Several doctors were consulted, including one who indicated that no surgical intervention would change the prognosis. Essentially, on clinical examination, he considered Zabala to be brain dead, and other doctors concurred that the prognosis was poor. Thus, it was determined that Zabala was not a good candidate for surgical intervention, and he slowly passed away. Zabala was ultimately pronounced dead at 2 p.m. on June 28, 2014. The cause of death was an anoxic brain injury with a massive cerebral edema and herniation. Zabala’s mother, acting individually and on behalf of both her son’s estate and his minor daughter, sued McAlpine; Roldan; and the deputies’ employer, the city of Oxnard. Zabala’s family alleged that the officers used excessive force in violation of Zabala’s rights and that the city was liable for the officers’ actions. Zabala’s family claimed that when one of the officers tackled Zabala to the ground, Zabala was unable to break his fall due to his hands being handcuffed behind his back. They alleged that as a result, Zabala violently struck the left side of his head against the asphalt. They also claimed that after Zabala injured his head, one of the officers punched Zabala several times and that the blows advanced the brain damage Zabala suffered in the fall. The family further claimed that Zabala’s behavior upon being admitted to the Ventura County jail was consistent with someone who was suffering from head trauma, including showing signs of nausea, possible vomiting, confusion, inability to understand questions, inability to communicate, lack of balance, and belligerent or strange behavior. Thus, they claimed Zabala fell in his cell when he suffered lost consciousness. Plaintiffs’ counsel, based on the opinion of doctors that were consulted, asserted that the head injury that caused the subdural hematoma occurred several hours before the fall in the jail cell. Counsel contended that the cerebral hematoma bled slowly and filled the cranial cavity, putting pressure on the blood vessels until they were constricted enough to cease flow, cutting off the blood supply to the brain, and causing the ultimate loss of consciousness and cessation of neurological activity. Thus, counsel asserted that Zabala’s fall inside the safety cell occurred as a result of a loss of consciousness. Plaintiffs’ counsel asserted that Zabala’s head condition was corroborated by the lack of skull fractures, which would have been expected in a fall serious enough to cause immediate loss of consciousness, breathing, and neurological activity. Counsel also contended that although various people posited that methamphetamine abuse may have contributed to the event, the emergency room physician on the subject date did not observe symptoms consistent with present intoxication at the time of his examination. However, plaintiffs’ counsel consulted with a doctor who specializes in drug intoxication and addiction issues, and contended that the detection of methamphetamine in the blood is not conclusive, as it takes at least three days for the drug to dissipate from the body. Defense counsel asserted that Zabala did not suffer an injury at the time of his arrest and that the scrapes on Zabala’s face were from being handcuffed on the asphalt. Counsel also asserted that the subdural hematoma was caused by Zabala’s fall inside the jail cell and not from anything that did or did not occur during his arrest., During his arrest, Juan Zabala suffered various bruises, scrapes, and abrasions to his left cheek, arms, wrists, hands, torso, back, knees, and feet. His family also claimed that his head violently struck the ground and was punched repeatedly by an officer. However, defense counsel claimed that Zabala’s head trauma was caused by his fall in a jail cell. Regardless, Zabala was found to be unconscious and unresponsive. CPR was performed and he was transported to Community Memorial Hospital while in cardiac arrest. Although medical personnel were able to get Zabala breathing again, a CT scan indicated that there was a cerebral edema and an impending herniation. The brain scan identified an intracranial hemorrhage and a marked brain edema with near total compression of the ventricular cisterns and loss of sulci. In addition, there was no evidence of neurological activity. As a result, it was determined that Zabala was brain dead and not a good candidate for surgical intervention. He was ultimately pronounced dead at 2 p.m. on June 28, 2014. The cause of death was determined to be due to an anoxic brain injury with a massive cerebral edema and herniation. Zabala was 32 years old. He was survived by his 15-year-old daughter and his mother, plaintiff Aurora Zabala. Plaintiffs’ counsel contended that the decedent’s daughter and her father were in the process of working on their relationship, which is why Mr. Zabala was so insistent on getting his records copied before the incident. Counsel contended that it was an effort to get his life together. Although Mr. Zabala spent most of his time in prison for crimes mainly involving drugs during his daughter’s lifetime, he allegedly told his daughter that he could not keep up with his “crazy life” anymore and admitted that he “screwed up.” Plaintiffs’ counsel also contended that Mr. Zabala told his daughter that he would straighten up and go to drug counseling, and that, in fact, the incident occurred outside of the drug counseling center that Mr. Zabala was attending. Counsel further contended that Mr. Zabala’s daughter was extremely close with her father prior to the incident and that she went to see him at the prisons and jails where he was incarcerated. In addition, counsel noted that Mr. Zabala kept a box full of letters and items that his daughter sent him, including every drawing, toy and card. Thus, the decedent’s family sought recovery for wrongful death damages. Plaintiffs’ counsel asserted that Mr. Zabala’s death caused his daughter to lose out on the promise of her father getting better and becoming more involved in her life. Counsel also noted that Mr. Zabala’s daughter, a star athlete before her father’s death, had plans to attend universities that were around $40,000 to $60,000 per year.