On April 17, 2015, plaintiff Melissa Alvarez, 33, a juvenile hall counselor of the Department of Probation in Napa County, was driving her 2005 GMC Yukon on Napa Vallejo Highway, also known as State Route 221, in the county of Napa. Alvarez’s son, plaintiff Lorenzo Alvarez, 3, was seated in a child seat placed in the rear, middle, passenger seat. At their location, the highway has two northbound lanes and a merge lane. As Alvarez was traveling in the right, number two, northbound lane, her vehicle was struck by a street sweeper operated by Harold Heimbingner, an employee of Syar Industries Inc. Heimbingner was driving a street sweeper on northbound SR-221 to clean up gravel that was previously spilled in the merge and right lanes by truck traffic out of the Syar Industries’ Napa Quarry. However, when Heimbingner attempted to make a U-turn, he turned left into the number two lane and struck the Alvarez vehicle in the process. As a result, Alvarez claimed to her chest, left foot, and right leg, knee and ankle. Lorenzo sustained to his foot. Alvarez, action on behalf of herself and Lorenzo, sued Heimbingner and Syar Industries Inc. Alvarez alleged that Heimbingner was negligent in the operation of the street sweeper and that Syar Industries was liable for Heimbingner’s actions while in the course and scope of his employment. The matter was consolidated with another case, which had William Snowden listed as a defendant. However, that case (and Snowden) was ultimately dismissed. Heimbingner was also dismissed from the case in exchange for a waiver of costs after Syar Industries admitted vicarious liability. In addition, on the first day of trial, the parties agreed that Alvarez was not comparatively at fault., As a result of the collision, Alvarez sustained a transverse fracture of the right, mid-shaft femur with lateral displacement; a fracture of the right tibial plateau; a fracture of the right, comminuted fibula; a bimalleolar fracture of the right ankle; and displaced fractures of the fourth and fifth phalanges in her left foot. She also sustained several seat belt contusions, abrasions to various areas of her body, abrasions to her left hand, and right-sided rib fractures. In addition, she complained of pain to her back, neck and chest. Alvarez never lost consciousness, and her vehicle caught fire as she struggled to remove her seat belt to get to her crying son. However, as a result of the multiple fractures to her right leg, Alvarez was unable to open her door, get out of her seat, or take her son out of the burning vehicle. Two Good Samaritans ultimately came on the scene, forced the driver’s side door open and dragged Alvarez out of the vehicle, causing abrasions and road rash on her buttocks and legs. During the rescue, Alvarez begged them to go back into the burning vehicle to save her child, which they did. Alvarez was transported via ambulance to an emergency room, where she underwent a retrograde, intramedullary nailing of her right femur and open reduction of her bimalleolar ankle fracture. On April 22, 2015, she underwent open reduction and internal fixation of her right bimalleolar ankle fracture, and open reduction and internal fixation of her tibia plateau fracture. As a result of nonunion of the fibular fracture, Alvarez underwent open reduction and internal fixation of her fibula on Oct. 16, 2015, and open reduction and internal fixation of syndesmosis, or high ankle ligaments, in the right leg, as well as removal of the previously implanted hardware in the right ankle. As a result of ongoing pain to her right knee and right hip, Alvarez underwent a corticosteroid injection in her right knee on Jan. 14, 2016, and a corticosteroid Injection in her right hip on Feb. 8, 2016. In addition, Alvarez underwent an arthroscopy and debridement of her right knee on March 23, 2016, and an arthroscopy and debridement of her right ankle on Aug. 1, 2016. As a result of the multiple fractures to her right leg, Alvarez claimed that she has ongoing pain and decreased range of motion in her right ankle, and ongoing pain in her right knee. She alleged that her pain causes her to limp, which has altered her gait and had resulted in pain to her hips and back. Alvarez further claimed that while she is physically able to run, it is painful and she has been advised not to do it. In addition, she claimed that she has been advised not to do anything that requires bending, squatting, twisting, putting weight/pressure on her knee, and other such motions, as they will rapidly speed up the deterioration of her knee and ankle, which are already significantly damaged. The plaintiff’s treating physicians opined that Alvarez’s future care needs during her life time included two to three knee arthroscopies, a knee replacement, an ankle arthroscopy, an ankle fusion and/or an ankle replacement. However, they testified that the future care needs and timing of the procedures depend on Alvarez’s ability to tolerate her pain. Alvarez’s treating physician opined that the future ankle fusion would occur three to five years from the date of the incident. He also opined that the fusion could be taken down at approximately age 55, at which time an ankle replacement could be accomplished with revisions once the life of the replacement had run its course, with subsequent revisions to take her out to the rest of her life expectancy. Plaintiffs’ counsel noted that juvenile hall counselors are trained peace officers that are required to restrain youth at a moment’s notice. They go through rigorous physical training every year, and they have to be able to restrain teen youth, which include males larger than Alvarez. Plaintiffs’ counsel contended that youth that pose a risk to others or themselves sometimes have to be wrestled to the ground and that given Alvarez’s , Alvarez is no longer able do that without causing further severe damage to her knee and ankle. Thus, Alvarez claimed that she is losing her career as a juvenile hall counselor with the Probation Department at Napa County and that she had no current prospect of staying with the county of Napa. She alleged that as a result, she will incur a future income loss ranging from $800,000 to $3 million, depending upon whether she would be able to return to some type of a job with Napa County. Thus, Alvarez sought recovery of $700,000 to $1.4 million in future medical expenses, $800,000 to $3 million in future loss of income, and an unspecified amount for her loss of household services. She also sought recovery of $5 million to $7 million in non-economic damages for her past and future pain and suffering. The parties stipulated that Alvarez’s past medical expenses totaled $295,000 and that Alvarez’s past loss of earnings totaled $28,000. Lorenzo complained of left foot pain and was subsequently examined at the emergency room. He underwent X-rays, which were negative, and was ultimately diagnosed with a probable contusion to his left foot. As a result, Lorenzo was given a splint, but he did not require any further treatment. On the third day of trial, the parties stipulated that Lorenzo’s past medical expenses totaled $4,047.67. He also sought recovery of $100,000 to $125,000 in non-economic damages for his past pain and suffering, and $50,000 to $100,000 in non-economic damages for his future pain and suffering. Thus, plaintiffs’ counsel asked the jury to award Alvarez and Lorenzo $11 million to $15 million in total damages. Defense counsel also did not dispute Alvarez’s past losses, and the defense’s expert orthopedic surgeon testified in deposition that Alvarez would eventually need a partial knee replacement and ankle fusion. However, defense counsel disputed the amount of Alvarez’s alleged future losses, and argued that Alvarez’s future medical expenses would only total between $200,000 and $300,000, and future income loss would total between $600,000 and $900,000. Counsel also argued that the amount of Alvarez’s past and future non-economic damages would only total $2.5 million. As for Lorenzo, defense counsel argued that Lorenzo’s past and future non-economic damages would only total $20,000. Thus, defense counsel suggested that the jury award damages totaling closer to $5 million for Alvarez and Lorenzo.