Arbis Shipley was the president of Sea Horse Ranch, Inc. (the ranch) (defendants), which operated a horse ranch bordering California Highway 1. One night after dark, Viola Scheutrum was driving on the highway past the ranch when her car struck a loose horse running on the highway. Scheutrum was killed in the accident. When the police arrived, eight horses were running freely on the highway, all of which had escaped from a corral on the ranch’s property. The fence surrounding the corral was completely dilapidated and lacked common features for securing horses, including wires usually installed to keep horses away from enclosure fences. The ranch had no perimeter fence separating its property from the highway. Horses had previously escaped from the ranch and wound up on the highway on multiple occasions, and Shipley had been aware of those incidents, including one in which he was cited by the Humane Society for having horses loose on the highway. Both the ranch and Shipley were charged with involuntary manslaughter. The ranch and Shipley alleged that Shipley had no knowledge of the negligent condition of the fence. The ranch and Shipley’s motion to have the charges dismissed was denied by the superior court, and the ranch and Shipley sought writ review of the denial of their motion.