On March 6, 2017, plaintiff John Hernandez, a 34-year-old unemployed man, was perceived to be acting suspiciously outside of a pharmacy on Alhambra Street, in Sacramento. Video showed Hernandez appearing agitated and possibly under the influence of drugs. Bystanders called 9-1-1, and police officers Michael Hight, Ismael Villegas and Casey Dionne responded to the scene. Hernandez ran across the street to a medical office building. The officers pursued Hernandez and shocked him at least 10 times with a Taser, beat him with batons and physically restrained him. Hernandez went into cardiac arrest and sustained a massive anoxic brain injury. Hernandez’s wife, Jennifer Hernandez, acting as her husband’s guardian ad litem, sued the city of Sacramento. Ms. Hernandez alleged that the officers’ actions constituted assault and battery, were in violation of California civil code § 52.1, and were in violation of Mr. Hernandez’s civil rights guaranteed to him by 42 U.S.C. § 1983. She also alleged that the city was liable for the officers’ actions. Ms. Hernandez also filed a claim on behalf of Mr. Hernandez’s minor daughter, referenced as “H.E.” in court filings, alleging interference with a familial relationship. The lawsuit was later amended to include individual claims against police officers Hight, Villegas and Dionne. Police officers Robert Harrison, Allison Cunningham, Daniel Paiz and Kevin Spring, who relieved Hight, Villegas and Dionne at the scene, were also later added to the lawsuit. Plaintiffs’ counsel contended that Mr. Hernandez was unarmed and not suspected of a violent crime. Counsel asserted that the officers used excessive force to restrain Hernandez. Plaintiffs’ counsel contended that Hight tackled Hernandez and shocked him with a Taser in drive stun mode several times. Counsel also contended that Villegas struck Hernandez with a baton before shocking him with a Taser several more times. Counsel contended that Villegas, who weighed more than 300 pounds at the time, then pressed his chest against Hernandez’s back for between seven and 10 minutes. Plaintiffs’ counsel asserted that Villegas’ actions constituted compressive restraint and that Hernandez was not moving during the last two to three minutes of the restraint. Plaintiffs’ counsel maintained that paramedics were called when Hernandez became unresponsive after a couple of minutes of being restrained. As evidence, counsel pointed to the paramedics’ report from the scene, which indicated that Hernandez was lying on the ground when they arrived at the scene. The paramedics also testified at depositions that Hernandez had agonal respirations and no heartbeat when they arrived. Plaintiffs’ counsel also pointed to eyewitnesses who claimed that Villegas threatened to “f–k up” Hernandez. Counsel also noted that TASER International sent Sacramento’s police department a bulletin in 2013, warning users not to apply repeated prolonged activations of the Taser while in drive stun mode. Plaintiffs’ counsel asserted that Hight and Villegas violated the warning bulletin and failed to take proper safety precautions. Counsel contended that the Sacramento Police Department failed to distribute the bulletin to its officers and that as a result, Hight and Villegas did not know about TASER International’s warnings. Defense counsel maintained that the officers’ actions were justified because Hernandez was violently struggling and kicking his legs throughout the incident. Counsel also maintained that Villegas only pressed on top of Hernandez for between 40 and 90 seconds and that Hernandez did not show any signs of medical distress during that time. Defense counsel asserted that paramedics were not called because Hernandez needed medical attention, but, rather, were called pursuant to policy, which states paramedics must be contacted when a Taser is used. Counsel also maintained that Hernandez was sitting up and breathing normal when paramedics arrived. In addition, defense counsel denied that Villegas threatened Hernandez., Hernandez went into cardiac arrest and had to be revived at the scene via CPR. Paramedics transported him to Sutter Medical Center, in Sacramento, where Hernandez was determined to have suffered an anoxic brain injury and was placed in a medically induced coma. Hernandez initially required dialysis, a feeding tube and a ventilator. He also had surgery to relieve the pressure on his brain. Hernandez also sustained soft tissue during the incident, but they were minor and resolved quickly. Hernandez started to decline, and his family considered taking him off life support. However, he woke up from his coma after 10 days. He is left with severe brain damage that initially left him with the mental capacity of a toddler. Hernandez was in the hospital for a total of 50 days, during which time he underwent rehabilitation before being sent home. He continued with physical therapy and speech therapy after leaving the hospital. He had to re-teach himself how to walk, talk, eat and tie his shoes. While Hernandez’s condition has improved, he still has slurred speech and short-term memory loss. He also lacks executive functions and, thus, requires 24-hour care. His mother and her boyfriend currently help him with cooking, cleaning and personal hygiene. They also drive him to doctors’ appointments, and Hernandez continues to undergoing both physical therapy and speech therapy. Plaintiffs’ counsel presented a life care plan that included continued physical therapy and doctors’ visits. It also included the cost of an attendant to assist Hernandez with daily tasks so that he no longer has to burden his aging mother with that responsibility. Counsel also wanted to get Hernandez into an inpatient rehabilitation facility for six months. Hernandez used to enjoy skateboarding, but he is no longer able to participate in that activity. While he was not working at the time of the incident, he had previously performed physical labor jobs. However, his have left him unable to work. Ms. Hernandez sought recovery of Mr. Hernandez’s past and future medical expenses, and damages for her husband’s past and future pain and suffering. Their 7-year-old daughter also sought recovery of damages for her own emotional pain and suffering. Defense counsel did not dispute the extent of Mr. Hernandez’s or the amount of damages alleged. However, defense counsel argued that the police’s actions did not cause Hernandez’s cardiac arrest and, instead, maintained that Hernandez was under the influence of methamphetamine at the time of the arrest. Counsel also argued that the drug use combined with Hernandez’s arrest resistance led to an excited delirium, which is characterized by agitation, aggression, acute distress and sudden death, and that this condition caused the cardiac arrest. In response, plaintiff’s counsel asserted that the excessive shocking with a Taser led to a cardiac arrhythmia and that Villegas’ compression restraint of Hernandez led to the cardiac arrest.