On Oct. 4, 2011, plaintiff Maryanne Knight, 50, an IT manager, was traveling in her 2003 Toyota on southbound U.S. Highway 101. When she was just south of the La Cumbre overcrossing, her vehicle was struck by a 2008 Ford F-550 operated by Melvin Dworak, III. The impact caused both vehicles to go off the highway, through the guardrail, and into a tree. Knight claimed to her pelvis, sacrum, and left leg. Knight sued Dworak and Dworak’s employer, Ramsey Asphalt Construction Corp. Knight alleged that Dworak was negligent in the operation of his vehicle and that Ramsey Asphalt was vicariously liable for Dworak’s actions while driving in the scope of his employment. Dworak later died of unrelated causes prior to trial. Knight contended that Dworak made an unsafe lane change and struck her vehicle. Ramsey Asphalt admitted that it was liable for any negligence of its employee, Dworak. However, it claimed that if Dworak was negligent, then Knight was also negligent. Defense counsel argued that Knight was driving too fast for the wet road conditions and that Knight was the one who made an unsafe lane change and caused the collision., Knight sustained fractures to her pelvis, sacrum, and left leg, including fractures to her femur, tibia and fibula. She was subsequently taken to Santa Barbara Cottage Hospital, in Santa Barbara, and underwent intramedullary rodding of her femur that day. Three days later, she underwent open reduction and internal fixation of the tibial fractures with plates and screws. Knight was off of work for 11 months, but ultimately returned to her position on a part-time schedule. However, she claimed she will eventually require joint replacement surgeries on her left knee and left ankle. Thus, Knight sought recovery of $238,526 in past medical costs, $450,568 in future medical costs, $90,194 in past lost earnings, and $1,774 in future lost earnings. She also sought recovery of damages for her past and future pain and suffering. Defense counsel acknowledged that Knight did sustain serious . However, defense counsel disputed the claim that Knight would need future knee and ankle replacement surgery.