On May 21, 2015, plaintiff Michael Hartsell became the subject of a search-and-arrest warrant. A U.S. Drug Enforcement Administration-organized, multi-agency narcotics task force converged upon Hartsell’s home, which was located in Vista. The agents knew that Hartsell was a convicted felon with a lengthy criminal history involving drugs. His criminal history did not include a conviction for a violent crime, but the agents did not know whether he possessed a weapon. When the agents approached the residence, Hartsell and a friend fled into the neighborhood. The agents identified Hartsell as one of the fleeing men and pursued him. Hartsell attempted to jump a fence, but he fell and struck his head. He then crawled into bushes. The agents established a perimeter, and they radioed for additional law-enforcement personnel, including a request for canine assistance. A sheriff’s deputy’s canine performed the first attempt to apprehend Hartsell but was not successful. The task was relayed to deputy Trenton Stroh, whose canine had been trained to bite and hold. Stroh’s canine eventually located Hartsell. Hartsell ignored a warning to surrender, so the canine was deployed. The animal locked onto and bit Hartsell’s left arm while another deputy pointed a gun at Hartsell. Hartsell was ordered to show his hands and emerge from the bushes. He surrendered and was apprehended within a minute. Hartsell sued Stroh and Stroh’s employer, San Diego County. The lawsuit alleged that Stroh’s actions constituted battery and unreasonable force in violation of the Fourth Amendment. At the summary judgment stage, the court found that the initial deployment of Stroh’s canine was reasonable as a matter of law, but that an issue of fact existed as to whether the continued use and duration of the canine bite was reasonable. Plaintiff’s counsel contended that Hartsell was only wearing a T-shirt and boxer shorts at the time of the incident and that the agents would have seen there was no place for Hartsell to keep a weapon. Plaintiff’s counsel also contended that the bushes were not thick and that Hartsell could have been seen through the bushes, so the canine should have been removed prior to making Hartsell crawl out. Plaintiff’s counsel noted that Stroh testified that Hartsell showed his hands and that once Hartsell did, the canine should have been removed. Plaintiff’s counsel argued that Stroh’s canine had a violent history, was on his third handler in three years and did not always release its bite upon verbal command. Plaintiff’s counsel also noted that the canine’s training history included four prior incidents in which it failed to promptly respond to a release command. Stroh claimed that he had been advised that several canine announcements had been made from the location where both suspects were last seen. He also claimed that he he had been advised that Hartsell was wanted on a felony arrest warrant for drugs, that Hartsell had an extensive criminal history, and that it was unknown whether either suspect was armed. Stroh further claimed that he could not physically access Hartsell or the canine in the bushes during the engaged bite and that Hartsell needed to be searched for weapons before the canine could be removed. Defense counsel acknowledged that Hartsell crawled approximately 5 to 15 feet to the edge of the bushes before the canine was removed but contended that the crawl and removal of the canine took approximately 30 to 45 seconds. As such, defense counsel argued that the continued use of the canine and duration of the bite was reasonable because of the uncertainty of whether Hartsell had any weapons, Hartsell’s drug history, and Hartsell’s potential to flee., Hartsell suffered a puncture wound of his left arm, resulting in deep tissue wounds. He was arrested, treated by medical personnel on scene, and transported to Tri-City Medical Center, in Oceanside, for further treatment. At the hospital, Hartsell’s left arm was treated with irrigation and drainage, debridement of skin and subcutaneous tissue, a skin graft to the left axilla, and a vacuum assistant closure procedure. He later underwent multiple surgeries addressing complications with the skin graft and cellulitis. He was in the hospital for months. Plaintiff’s counsel noted that Hartsell developed sepsis and that Hartsell was left with numbness and tingling in his fingers. Hartsell sought recovery of past and future medical costs and damages for his past and future pain and suffering.