Ramirez v. County of Riverside CA4/2
E081911
| Cal. Ct. App. | Dec 9, 2024Background
- Plaintiff Daisy Ramirez was seriously injured and rendered paralyzed in a 2017 traffic accident on Grapefruit Boulevard in Riverside County, CA, when another vehicle attempted to pass and struck another car, which then collided with Ramirez.
- Ramirez (through her conservator) sued the County of Riverside, claiming the road's design—a single broken yellow centerline allowing passing—constituted a dangerous condition that caused her injuries.
- The County moved for summary judgment, contending, among other defenses, that it was immune from liability under the design immunity doctrine.
- The trial court granted summary judgment in favor of the County, finding that design immunity applied and Ramirez had not shown a triable issue of material fact.
- On appeal, the appellate court reviewed the record (despite deficiencies in Ramirez’s appellate filings) and affirmed the summary judgment for the County.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the County created a dangerous road | Allowing passing (single broken line) made the road dangerous | Roadway design complied with standards; no dangerous condition | Design immunity applies; no triable issue |
| Applicability of design immunity | County not entitled since design is now unreasonably dangerous | All elements of design immunity met: plan, discretionary approval | County entitled to design immunity |
| Loss of design immunity by changed conditions | Road has become dangerous due to accident history | No material change in physical conditions; no qualifying evidence | No loss of immunity; no triable issue |
| Duty to warn of concealed trap | Lack of warning created a concealed trap | No evidence of any concealed trap or hidden roadway feature | No duty to warn; no concealed trap present |
Key Cases Cited
- Regents of University of California v. Superior Court, 4 Cal.5th 607 (Cal. 2018) (summary judgment standards under California law)
- Carnes v. Superior Court, 126 Cal.App.4th 688 (Cal. Ct. App. 2005) (de novo appellate review of summary judgment)
- Cornette v. Department of Transportation, 26 Cal.4th 63 (Cal. 2001) (elements and rationale of design immunity defense)
- Gonzalez v. Mathis, 12 Cal.5th 29 (Cal. 2021) (standards for de novo review on summary judgment)
- Grenier v. City of Irwindale, 57 Cal.App.4th 931 (Cal. Ct. App. 1997) (summary judgment and substantive analysis of design immunity)
- Cerna v. City of Oakland, 161 Cal.App.4th 1340 (Cal. Ct. App. 2008) (application of pleadings to design immunity defense analysis)
- Laabs v. City of Victorville, 163 Cal.App.4th 1242 (Cal. Ct. App. 2008) (evidence sufficient for discretionary approval of design)
- Tansavatdi v. City of Rancho Palos Verdes, 14 Cal.5th 639 (Cal. 2023) (design immunity does not shield against failure to warn of concealed traps)
- Anderson v. City of Thousand Oaks, 65 Cal.App.3d 82 (Cal. Ct. App. 1976) (liability for failure to warn of concealed traps in road design)