Meddock v. County of Yolo CA3
220 Cal. App. 4th 170
Cal. Ct. App.2013Background
- Meddock was injured when a Fremont cottonwood tree fell onto him in a paved parking lot at Elkhorn Regional Park, owned by the County of Yolo.
- Plaintiff alleged the county failed to maintain dangerous trees and warned users, asserting a dangerous condition of public property.
- The trial court granted summary judgment for the County, applying Government Code section 831.2 immunity for injuries caused by a natural condition of unimproved public property.
- Meddock argued that his injury occurred on improved property and thus immunity did not apply; he also noted nearby trees leaning over the lot and mistletoe infestation.
- The appellate court held that the injury was caused by a natural condition of unimproved property (the trees) located near or adjacent to the improved area, so 831.2 immunity applies despite the patch of improved property where the incident occurred.
- Disposition: judgment affirmed for the County with Meddock bearing costs.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether 831.2 immunity applies to injuries caused by a natural condition on unimproved property when the injury occurs on improved property. | Meddock contends immunity should not apply because the injury happened on an improved area used for its intended purpose. | County argues the injury was caused by a natural condition of unimproved property and thus immune regardless of where on the property the injury occurred. | Yes, immunity applies; injury was caused by a natural condition on unimproved property. |
| Whether proximity or location of the improved vs unimproved areas affects the applicability of 831.2. | Proximity to improved areas could suggest non-application of immunity. | Location is not determinative; causation by a natural condition governs immunity. | Location not controlling; causal connection to unimproved property governs immunity. |
| Whether the action survived summary judgment given the plaintiff’s asserted notice or danger theories. | Claim that trees were deteriorating and dangerous should defeat immunity. | Immunity does not require awareness of the danger to apply; warned or known dangers do not defeat immunity. | Immunity applied; plaintiff failed to create triable issue against 831.2. |
Key Cases Cited
- Milligan v. City of Laguna Beach, 34 Cal.3d 829 (Cal. 1983) (affirms natural condition immunity; discusses cost concerns and public-use policies)
- Smith v. County of San Mateo, 62 Cal.App.2d 122 (Cal. App. Dist. 2 1943) (legacy liability under prior regime; decaying trees in park context)
- Ladd v. County of San Mateo, 12 Cal.4th 913 (Cal. 1996) (defines 'caused by' in government immunity contexts; broad interpretation)
- Aguilar v. Atlantic Richfield Co., 25 Cal.4th 826 (Cal. 2001) (three-step framework for reviewing summary judgments in government claims acts)
- Arroyo v. State of California, 34 Cal.App.4th 755 (Cal. App. 1995) (natural hazard immunity in park-like settings; proximity and warning principles)
- Peterson v. San Francisco Community College Dist., 36 Cal.3d 799 (Cal. 1984) (warning/land-use considerations within immunity analysis)