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Kollerbohm v. County of Los Angeles
A deputy sheriff employed by the County of Los Angeles caused an accident when he fell asleep at the wheel of his vehicle. The deputy was later diagnosed with severe sleep apnea. A jury trial in the subsequent lawsuit brought by a motorist injured in the accident ended with a special verdict finding no negligence, the jury concluding the deputy was disabled by a sudden or unexpected physical condition which he could not reasonably have anticipated. The trial court granted the motorists motion for judgment notwithstanding the verdict, as well as his motion for a new trial, and the deputy and County appealed. Because there was insufficient evidence the deputy fell asleep suddenly or without warning, court affirm the order granting the motorist judgment notwithstanding the verdict.

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