On March 12, 2017, plaintiff Cedric McGilberry, 49, a truck driver, was transporting goods from Richmond, Calif., to Reno, Nevada. As he was driving his tractor-trailer on Interstate 80, in Truckee, he rounded a curve in the road and collided with a sander operated by Cedric Dodson. Prior to the incident, Dodson was applying material — sand and salt — to Interstate 80 in case of black ice. As Dodson proceeded across the Donner Lake Road overpass, he decided he needed to apply more material to the bridge deck. As a result, he planned to exit the freeway in order to loop around and re-enter Interstate 80 heading in the westbound direction. Rather than exit the freeway using one of the designated off-ramps, Dodson opted to exit the interstate by backing down the eastbound on-ramp from Donner Lake Road. In order to do so, Dodson was required to use a maneuver, which involved him making a U-turn on the freeway, across the oncoming traffic lanes, and driving the wrong-way, in the opposite direction of traffic, down the eastbound on-ramp. Dodson slowed his vehicle as he merged onto the left shoulder/center divide of eastbound I-80, just past the overpass, in order to prepare for his U-turn. He then began his U-turn, but was unable to complete it, causing his vehicle to stop perpendicular to the roadway with the rear of the sander blocking the number two lane of traffic. Dodson was allegedly about to back up when McGilberry’s tractor-trailer collided with Dodson’s sander. The tractor was obliterated, and McGilberry sustained to his head, face, a hand, a knee and a shoulder. McGilberry sued Dodson; and Dodson’s employers, the State of California Department of Transportation, the state of California and the State of California Department of Transportation Division of Equipment. McGilberry alleged that Dodson was negligent in the operation of the sander and that Caltrans, the State and the Division of Equipment were liable for Dodson’s actions while in the course and scope of his employment. Plaintiff’s counsel contended that Dodson admitted that he was not applying material to the roadway when this incident occurred, but, rather, Dodson had raised his plow and had turned his sander off before initiating his U-turn. As a result, counsel asserted that Dodson’s actions violated Vehicle Code § 21054, which states that operators of maintenance equipment must abide by the Vehicle Code when traveling to and from their intended roadway work. Defense counsel asserted that Dodson acted appropriately and that Dodson’s employers were immune from liability pursuant to California Vehicle Code § 21053, which states that operators of maintenance equipment are exempt from complying with the provisions of the Vehicle Code while actually engaged on work on the surface of the roadway. Counsel also asserted that McGilberry was at-fault for the incident, citing GPS evidence taken from McGilberry’s truck, which showed that McGilberry did not slow his truck prior to the collision. In addition, defense counsel asserted that McGilberry had fallen asleep at the wheel., McGilberry sustained a traumatic brain injury, a concussion with a loss of consciousness more than 15 minutes, a skull fracture, orbital fractures, multiple facial fractures, wrist and finger fractures, a knee sprain, a cervical sprain and a rotator cuff tear. He also claimed he suffered an impingement of a shoulder, post-traumatic concussion syndrome, depression and adjustment disorder. McGilberry’s engine ended up inside the cab of the truck after the collision, and the door was crushed onto McGilberry. He recalled waking up in the cab of his truck, but became unconscious as he opened the door and tumbled out. McGilberry was transported by ambulance to a hospital, where he woke up with his mother, father and daughter by his side. McGilberry’s workers’ compensation case manager concluded that McGilberry was 10 percent disabled and would not be able to continue working as a truck driver. McGilberry also claimed that he requires ongoing psychological treatment. McGilberry sought recovery of $96,000 in past medical expenses and $100,000 in future medical expenses. He also sought recovery of lost earnings, and damages for his past and future pain and suffering.