On June 22, 2011, plaintiff Brittany Gilchrist, 28, a registered nurse, was driving with her children, plaintiff Cambria Gilchrist, 4, and plaintiff Shaelin Gilchrist, 1.5 months old, in child safety seats in the rear of her vehicle. While they were traveling on southbound State Route 41 in Madera County, their vehicle was struck head-on. Prior to the collision, at approximately 12:15 p.m., a Ford F-250 4×4 pickup truck operated by Michael Pritchett was traveling on northbound SR-41 when he experienced a failure of the left, front tire (a tread separation followed by a blow out) and lost control. As a result, Pritchett swerved into the southbound lanes of traffic and collided with the Gilchrist vehicle. A fire subsequently ensued in the Gilchrist vehicle and the Gilchrists had to be extricated from the vehicle. Both Brittany and Cambria Gilchrist claimed extensive . Brittany Gilchrist, acting individually and as guardian ad litem to her two daughters, Cambria and Shaelin, and their husband/father, Marc Gilchrist, sued Pritchett; the owner of the Ford pickup truck, Michael Pritchett Electric; the designer/manufacturer of the subject pickup truck, Ford Motor Co.; and the seller of the pickup, Lithia Fresno Inc. The Gilchrists alleged that Pritchett was negligent in the operation of his vehicle and that Michael Pritchett Electric was vicariously liable for Pritchett’s actions. They also alleged that Ford Motor defectively designed the pickup, and that Ford Motor and Lithia Fresno were strictly liable for failing to retrofit or recall the F-250. Lithia Ford was dismissed from the case on the first day of trial. Pritchett and Michael Pritchett Electric ultimately settled for their $1.5 million policy limits in a Minors’ Compromise/Good Faith Settlement in May 2012. In Pritchett’s statement to police, he claimed that after his tire failed, he braked as hard as he could and attempted to steer to the right, but that he could not steer the vehicle and crossed over the double yellow lanes into oncoming traffic. The impact had a Delta V of 51 mph. Thus, the matter proceeded to trial against Ford Motor only. The plaintiffs’ vehicle design expert testified that the testing he performed in November 2011 showed that the steering efforts are over four times harder in a “stomp and steer” event because the Hydro-Boost system provides fluid to both the brakes and the steering, while prioritizing the brakes. Thus, the expert opined that when a person applies the brakes hard in a panic situation, it then becomes manual steering. Plaintiffs’ counsel noted that The National Highway Transportation Safety Administration, through its Office of Defects Investigation, had an engineering analysis performed over 2000-02 as a result of complaints about diminished power steering in the Ford F-Series Four Wheel Drive (Pritchett’s vehicle) with anti-lock brakes when the vehicle was braked. Counsel contended that the Office of Defects Investigation found that this characteristic did exist and that it was not optimal. Counsel also contended that the Office of Defects Investigation found that the complaints vastly involved low-speed turning events, such as parking or backing up, although there were some high-speed events where there was emergency, hard braking and steering simultaneously. However, plaintiffs’ counsel contended that the analysis found that no one had been injured in the high-speed events and, thus, it was not labeled a defective condition. Plaintiffs’ counsel further contended that Ford Motor made changes in the scrub radius on its vehicle and had several suggestions on improving the flow to the steering system, but that it was unclear if Ford Motor followed through on those recommendations. In addition, plaintiffs’ counsel uncovered another event involving a driver (an electrical engineer) in Arizona who was driving on the freeway, had a left front tire failure in his 2000 F-250 4×4 diesel, encountered difficulty steering to the right, and went off the road. Plaintiffs’ counsel argued that there were brake marks in the road indicating that the driver braked when he steered and the driver in that accident testified about his experience at the Gilchrists’ trial. Ford Motor claimed that the Hydro-Boost had nothing to do with the subject accident and argued that Pritchett did not brake until about 45 feet before impacting the Gilchrist vehicle, which was too late to avoid the collision, according to experts on both sides. Ford Motor also claimed the marks from the left front tire failure on the F-250 showed Pritchett steered the truck left, demonstrating that he could steer the vehicle, which was contrary to the plaintiffs’ complaints concerning the Hydro-Boost system. Thus, Ford Motor claimed that the F-250 was not defective, and that its test engineers, the National Highway Traffic Safety Administration’s engineers, and even the plaintiffs’ vehicle design expert’s testing robot were all able to steer through any increased steering effort, which was minimal and not noticeable in a stomp-and-steer situation. Ford Motor alleged that the majority of complaints investigated by the National Highway Traffic Safety Administration involved low-speed or no-speed turning events, such as parking or backing up, and that very few complaints involved high-speed events requiring simultaneous emergency hard braking and steering. Moreover, it alleged that there were no reported in any complaints involving Ford vehicles. In addition, Ford Motor claimed that the scrub radius had nothing to do with high-speed “stomp and steer” events, which was supported by the National Highway Traffic Safety Administration’s testing and Ford Motor’s investigation. In response, plaintiffs’ counsel contended that their investigation of the accident scene uncovered a faint tire mark that was left on the double yellow lines separating SR-41, which they claimed was missed by California Highway Patrol Officers. Counsel argued that this mark demonstrated that Pritchett braked early in the accident, activating his vehicle’s ABS system, explaining why there were no brake marks until before the vehicles collided. However, Ford Motor’s counsel responded that there would be continuous tire marks if Pritchett applied his brakes where he said he did, even if the ABS system had activated., Mrs. Gilchrist and her two daughters were taken from the scene of the accident and brought to hospitals. Mrs. Gilchrist was taken by air ambulance/helicopter to Community Regional Medical Center in Fresno, while her children were taken by ground ambulance to Children’s Hospital Central California in Fresno; however, Shaelin did not sustain any physical injury. Mrs. Gilchrist sustained a traumatic brain injury and lost consciousness during the accident. She also sustained carotid vascular , a left vertebral injury, a spleen laceration, left patellar tendinosis, a torn right medial meniscus, and an avulsion of her left internal and external obliques and transverse muscles. Mrs. Gilchrist also suffered fractures to her left ribs and sternum, left clavicle, both femurs, right tibia and fibula, and right patella. She subsequently underwent open reduction and internal fixation surgery to treat both femur fractures on June 23, 2011. On the same date, she underwent an incision and drainage, external fixation, and multiplanner of her right tibia fracture, as well as a closed treatment for her patella fracture. The following day, the external fixator was removed, followed by irrigation, debridement and intramedullary nailing. Mrs. Gilchrist claimed that she suffers cognitive impairments as a result of her head injury. She also claimed she suffers from adjustment disorder with mixed depression and anxiety, as well as chronic pain from her physical . In addition, Mrs. Gilchrist claimed she was fired from her job as a neonatal intensive care unit nurse in October 2011 and cannot return to work as an registered nurse. Thus, Mrs. Gilchrist sought recovery of $235,224 in past medical costs, $2,366,104 in future medical costs, $2.4 million to $2.8 million in total lost earnings (present value), and $9.1 million in general damages. Cambria suffered multisystem trauma, including pancreatic failure and a Grade 1 liver laceration of the left lobe. She also suffered fractures of the right epicondyle, the left humeral neck, anterior ribs, left proximal humerus and right distal humerus. She was subsequently hospitalized at Children’s Hospital from June 22, 2011, through July 19, 2011. Cambria claimed she suffers from post-traumatic stress disorder as a result of the accident. In addition she underwent an MRI of her abdomen in September 2013, which showed atrophy of the body and tail of the pancreas, which was new from the previous study. Thus, Cambria sought recovery of $107,463.91 in past medical costs and $9.4 million in general damages. Shaelin, who was not seriously injured in the accident, but was brought to a hospital by ambulance for evaluation, sought recovery of $1,976 in past medical costs, as well as $100,000 in general damages. In addition, Mr. Gilchrist sought recovery of $500,000 in general damages, and the plaintiffs all sought recovery of punitive damages.