At around 3:20 a.m. on June 5, 2013, plaintiff Boram Teresa Choi, 27, an assessor at Ernst & Young, had exited Venice Boulevard and was driving on the on-ramp for the eastbound Santa Monica Freeway, also known as Interstate 10, in Los Angeles, when her vehicle veered to the right, went down a steep embankment, and struck a tree. Choi had no recollection of the events, and an investigating officer cited her as the sole cause of the incident. Choi sustained to her head, and subsequently made a workers’ compensation claim. Choi sued the state of California, alleging that the state failed to repair a dangerous condition of public property. The workers’ compensation carrier filed a complaint-in-intervention, seeking reimbursement of its lien and credit rights, if Choi recovered anything. The city of Los Angeles and the county of Los Angeles were also initially sued, but the city and county were both ultimately dismissed from the case. Choi’s counsel contended that a guardrail should have been present adjacent to the on-ramp, given the slope of the embankment, the drop height of over 20 feet, and the lack of a 30-foot recovery zone. As to any alleged budgetary constraints, counsel contended that the state could have implemented temporary measures through the Maintenance Department without having to wait for funding. The state’s counsel contended that the subject location did not require a guardrail. Counsel asserted that Choi was exclusively (or comparatively) responsible for the incident, as Choi drove while extremely sleep-deprived and fell asleep at the wheel. In addition, counsel asserted that Choi’s employer was responsible for allowing Choi to drive even though it knew that Choi was sleep deprived., Choi sustained a traumatic brain injury and was rendered partially paralyzed. She was subsequently taken immediately to a hospital. However, Choi claimed that she will never work again and that she requires around-the-clock, lifetime care. Thus, Choi sought recovery of damages for her life-long care.