California Codes
Cal. Government Code § 818.2 (2026)
✓ current as of May 2026
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A public entity is not liable for an injury caused by adopting or failing to adopt an enactment or by failing to enforce any law.
Notes of Decisions
Cited in 37
cases (8 in the last 5 years), 1969–2025 · leading case: Williams v. State of California, 664 P.2d 137 (Cal. 1983).
Williams v. State of California, 664 P.2d 137 (Cal. 1983). “Included amongst said acts of negligence was the failure to investigate the brake drum part to determine it was still hot, failure to identify other witnesses at the scene or even the other motorists damaged by brake drums, and failure to attempt any investigation or pursuit of…”
HFH, LTD. v. Superior Court, 542 P.2d 237 (Cal. 1975). “" (Gov. Code, § 818.2.) The zoning ordinance of which plaintiffs complain is, of course, an "enactment" within the meaning of section 818.”
San Diego City Firefighters v. Bd. of Admin. of San Diego City Employees' Ret. Sys., 206 Cal. App. 4th 594 (Cal. Ct. App. 2012). “(Gov. Code, § 818.2.) 14 Thus, we conclude that the trial court did not error when it sustained without leave to amend the demurrer of City to the negligence claim of Saathoff and Local 145.”
Adams v. City of Fremont, 80 Cal. Rptr. 2d 196 (Cal. Ct. App. 1999). “(b)) and for failure to enforce the law (Gov.Code, § 818.2, 821), as well immunities applicable to particular functions, such as confining or transporting certain persons.”
Locklin v. City of Lafayette, 867 P.2d 724 (Cal. 1994). “While the issue of liability solely for approving development of private property is not before us in this case, we note that public entities enjoy broad statutory immunity for such acts.”
Gates v. Superior Court, 95 Cal. Daily Op. Serv. 1146 (Cal. Ct. App. 1995). “) At another point in the analysis of the complaint in Susman , the court referred to the second cause of action and noted: "Insofar as it is alleged in the second cause of action that the State of California and the City of Los Angeles failed to disperse the crowd which had…”
Guzman v. Cnty. of Monterey, 209 P.3d 89 (Cal. 2009). “) It is also unnecessary to address whether any of the identified immunity statutes (Gov. Code, §§ 818.2, 818.4, 818.6, 820.4, 820.”
Eldridge v. City of Palo Alto, 57 Cal. App. 3d 613 (Cal. Ct. App. 1976). “(Gov. Code, § 818.2 and § 821. See HFH, Ltd.”
Guzman v. Cnty. of Monterey, 178 Cal. App. 4th 983 (Cal. Ct. App. 2009). “” The companion section, Government Code section 821, extends the same immunity to the public employee.”
Walt Rankin & Assocs., Inc. v. City of Murrieta, 2000 Cal. Daily Op. Serv. 8824 (Cal. Ct. App. 2000). “The closest immunities we have found are those that assertedly insulate a public entity from liability for damages caused by any activity related to the failure to enforce a law and/or to the granting or revoking, or refusal to grant or revoke, a license, permit, or other…”
Clausing v. San Francisco Unified Sch. Dist., 221 Cal. App. 3d 1224 (Cal. Ct. App. 1990). “) Government Code section 818.2, in turn, provides: “A public entity is not liable for an injury caused by adopting or failing to adopt an enactment or by failing to enforce any law.”
City of Oakland v. Hassey, 163 Cal. App. 4th 1477 (Cal. Ct. App. 2008). “) Because we have focused on Oakland’s potential liability with respect to withholding Hassey’s final paycheck, and not on any legislative or quasi-legislative action by the city, Government Code section 818.2 does not provide Oakland with immunity.”
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