On Aug. 29, 2016, plaintiff Lorraine Williams, a 67-year-old who suffers from severe dementia, end stage renal disease, diabetes and an amputated leg, was being transported by a non-emergency medical van to dialysis when the van made a turn on West Eighth Street, in Los Angeles, causing Williams to fall to the van’s floor. Williams sustained an injury to her left leg. Williams sued the owner of the van, G & H Non-Emergency Medical Transportation, LLC; and the hospital she was being transported from, Burlington Convalescent Hospital Inc. Williams alleged that the defendants were negligent for failing to strap/secure her prior to departing for the dialysis visit. G & H brought a cross-complaint against Burlington Convalescent Hospital, alleging that the hospital was to blame for not securing Williams. The hospital ultimately settled out of the case prior to trial, and the cross-complaint against the hospital was dismissed after Burlington settled with Williams. G & H ultimately conceded to liability after its counsel’s motions in limine regarding evidence related to liability issues were excluded by the court., Williams sustained a fracture of her left femur (the non-amputated leg). She was taken to a hospital, where she underwent an open reduction and internal fixation with the placement of an intramedullary nail. Williams remained hospitalized for eight days and then returned to another skilled nursing facility, where she remained throughout trial. Williams could not testify, as she was incapacitated due to her dementia and was restricted to a gurney. However, Williams was presented to the jury on her gurney at the opening of the trial. Plaintiff’s counsel argued that although Williams’ fracture was repaired, the injury had changed her quality of life. Counsel contended that Williams could no longer transfer to/from her wheelchair and was, therefore, confined to a bed. Counsel also contended that Williams felt that she did not trust anyone, so Williams could not be attended to by her caregivers in the same way after her injury, causing Williams to suffer from emotional distress. Plaintiff’s counsel asked the jury to award Williams $3 million in damages for her past and future pain and suffering. Defense counsel contended that Williams had the same medical issues before the accident as she after it. Counsel argued that Williams did not suffer any difference in her pain and suffering because Williams had completely healed from the fracture and that Williams’ current and future medical issues were caused by the natural progression of her dementia, end stage renal disease, diabetes, right leg amputation, peripheral artery disease, anxiety and depression.