On April 4, 2011, at approximately 11 a.m., plaintiff Mary Jane Caulder, 48, a store clerk for an auto body shop, was walking in the parking lot of her employer when she was struck on the right knee by a pickup truck operated by Darrel Lee Suhl, who was reversing out of a parking spot. Caulder claimed a fracture of her right knee, causing a prosthetic from a prior knee replacement to become dislodged. Caulder sued Suhl, alleging the defendant was negligent in the operation of his vehicle. Specifically, Caulder claimed Suhl was inattentive, and should have noticed her in either his mirrors or by turning his head around. Plaintiff’s counsel noted that the police report for the incident assessed fault on Suhl. Suhl contended that Caulder was mostly at fault for the incident, since two seconds before the impact Caulder answered her cell phone. He claimed that, as such, Caulder was inattentive and failed to notice the pickup truck reversing out of the spot., Caulder was taken from the scene of the accident by ambulance and brought to an emergency room. She sustained a fracture to the head of her tibial plateau, which she claimed caused the prosthetic from a prior right knee replacement to become dislodged. Caulder initially treated with physical therapy and had her knee placed in a brace for 1.5 years. On Nov. 27, 2012, she underwent a new total knee replacement, which was complicated by the fracture and required a special prosthetic with a hinge. Caulder claimed her pre-existing issues of pain and reduced mobility have worsened with the subject accident. She claimed that as a result, she hasn’t returned to work since the accident and is very limited physically. In addition, she claimed her physical therapy treatment has remained ongoing since the knee replacement. Thus, Caulder sought recovery of $125,000 in past medical costs, roughly $150,000 in future medical costs, $35,000 in past lost earnings, $100,000 in future lost earnings, and an unspecified amount of damages for her past and future pain and suffering. Defense counsel asserted that Caulder’s injury complaints were a result of her pre-existing condition, contending that the plaintiff’s original knee replacement was failing anyway.