Just after nightfall at around 8:15 p.m. on April 15, 2011, plaintiff Edd Crouch, 29, a sales trainee at a carpet cleaning business, was walking north on the walkway along Port Chicago Highway, in Concord. As he headed across the on-ramp to eastbound Highway 4, a pickup truck operated by Jose Rodriguez and traveling on northbound Port Chicago Highway angled right to take the freeway on-ramp. However, by the time Rodriguez angled right, it was too late for Crouch to get across, and by the time the pickup truck’s headlights illuminated Crouch, it was too late for Rodriguez to stop. As a result, Crouch was struck by Rodriguez’s pickup truck, causing to his head. Crouch sued Rodriguez; and the maintainers of the on-ramp, the city of Concord, the San Francisco Bay Area Rapid Transit District, and the state of California, via its Department of Transportation (Caltrans). Crouch alleged that Rodriguez was negligent in the operation of the pickup truck and that the remaining defendants failed to properly maintain the on-ramp, constituting a dangerous condition of public property. In 2013, Rodriguez agreed to tender his applicable insurance policy limits of $15,000 in order to settle with Crouch. The city also agreed to settle for $50,000, and Crouch dismissed his claim against the Bay Area Rapid Transit District. Thus, the matter continued against Caltrans only. Plaintiff’s counsel maintained that Caltrans is charged with fully considering the safety of pedestrians, bicyclists, and disabled persons at freeway on-ramps. This is especially true for pedestrian crossings at dual destination, multi-lane, free-flow, high-speed on-ramps. One such high-risk crossing is found at the on-ramp from northbound Port Chicago Highway onto eastbound State Route 4. However, plaintiff’s counsel contended that Caltrans did not consider pedestrian safety at this on-ramp. Specifically, counsel contended that there was no engineering analysis or design decision and that it just fell through the cracks. Plaintiff’s counsel noted that Caltrans installed a wheelchair curb cut on one side and partially installed a curb cut on the other side, but contended that Caltrans left the project unfinished. Counsel asserted that Caltrans left the crossing with no pedestrian protections whatsoever — no crosswalk markings, no advance yield lines, no warning signs, and no warning beacons. Thus, plaintiff’s counsel asserted that when Crouch attempted to cross at the area indicated by Caltrans’ curb cuts, he was struck by Rodriguez, who was sober, unhurried, and attentive. Counsel further asserted that as Rodriguez approached the on-ramp, he did not see any warning signs, markings, or signals and that Rodriguez did not expect to see any pedestrians on the poorly lit, weed-lined on-ramp. Caltrans’ counsel asserted that Rodriguez and Crouch were the only causes of the accident and that the incident location was not dangerous. Counsel contended that no signs were required and that during a 10-year period from 2001 to 2011, over 9.8 million vehicles traveled north through the subject intersection with zero similar vehicle-versus-pedestrian injury collisions., Crouch sustained severe head trauma, brain damage, and to his lower extremities. His condition was determined to be life-threatening and he was comatose for weeks after the incident. As a result of the initial subdural hematoma, as well as adjustments to his Coumadin therapy in the wake of the accident, Crouch later developed a second acute subdural hematoma that paralyzed one side of his body. Plaintiff’s counsel noted that Medicare paid $1,148,838.81 for Crouch’s medical expenses and that MediCal paid $74,896.47 for Crouch’s medical expenses. Based on the cost analysis of the plaintiff’s life care planner, and an estimated life expectancy of an additional 30 years, the cost of Crouch’s alleged future care needs, reduced to present value, was between $12,100,325 and $14,588,572.