On May 30, 2011, plaintiff Jeannetta Rizkalla, 48, a surgical nurse from Simi Valley, was visiting Santa Barbara with her husband, plaintiff Tarek Rizkalla, 50, a controller, over the Memorial Day holiday. They visited Santa Barbara frequently, and would take regular and long bike rides with their dogs by carrying the dogs in a small child’s trailer that was attached to Mr. Rizkalla’s bicycle. After visiting the chalk drawings at the Old Mission, they rode their bicycles west on East Los Olivos Street. When Mrs. Rizkalla was approximately 100 feet west of Anacapa Street, approaching State Street, she struck an area of uneven asphalt within the roadway, which was caused by the roots of a city tree. As a result, she crashed and sustained to her right, dominant elbow. Mrs. Rizkalla sued the city of Santa Barbara. She alleged the city negligently repaired and/or maintained the roadway, creating a dangerous condition of public property. Mrs. Rizkalla testified that she was not riding fast and that she had both hands on her handlebars at the time she hit the bump in the roadway. She claimed she did not see the uplifted section of asphalt before she hit it. The plaintiffs’ traffic expert and the Santa Barbara Police Department opined that the uplifted section of the roadway measured about 3 to 4 inches higher than the immediately adjacent surface of the asphalt roadbed. Plaintiffs’ counsel contended that the uplifted section of Los Olivos Street constituted a dangerous condition of public property within the meaning of Government Code § 835 of the Tort Claims Act. Counsel also contended that the city had constructive notice of the dangerous condition, as the city had performed a number of street and sidewalk repairs along Los Olivos Street and in the vicinity of the defect. Thus, plaintiffs’ counsel argued that the fact that the streets had been repaired numerous times before the accident should have alerted the city to the street defect. Defense counsel contended that the uplifted section of the roadway was not a dangerous condition to a due care user of the roadway. This contention was supported by the fact that the location of the defect was near the curb where cars parked and by the testimony of a nearby resident, who had noticed the condition on prior occasions but never reported it to the city. Defense counsel argued that even if the jury found that the condition of the roadway was dangerous, it should assess comparative fault to Mrs. Rizkalla for the negligent operation of her bicycle by not paying attention to roadway conditions., Mrs. Rizkalla went over the side of the handlebars of her bicycle and landed on the roadway. She subsequently sustained a complex Monteggia fracture of her right elbow, which consisted of a fracture of the proximal third of the ulna with dislocation of the head of the radius. Mrs. Rizkalla was taken to a hospital and underwent three surgeries. Mrs. Rizkalla claimed she was unable to work as a surgical nurse for over a year, resulting in $134,000 in past lost earnings. She also claimed she had $86,000 in past medical bills. In addition to seeking recovery for her past medical costs and past lost earnings, Mrs. Rizkalla sought recovery of over $740,000 in future lost earnings even though she had returned to work as a surgical nurse 1.5 years before trial and had been promoted to a higher level nursing position. Mr. Rizkalla presented a derivative claim, seeking recovery of damages for his loss of consortium. Thus, plaintiffs’ counsel asked the jury to award the Rizkallas $2,001,000 in total damages.