Cal. Codes » Government Code / TITLE 1. GENERAL / DIVISION 3.6. CLAIMS AND ACTIONS AGAINST PUBLIC ENTITIES AND PUBLIC EMPLOYEES / PART 2. LIABILITY OF PUBLIC ENTITIES AND PUBLIC EMPLOYEES / CHAPTER 1. General Provisions Relating to Liability / ARTICLE 2. Liability of Public Entities
California Codes

Cal. Government Code § 818.4 (2026)

✓ current as of May 2026
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A public entity is not liable for an injury caused by the issuance, denial, suspension or revocation of, or by the failure or refusal to issue, deny, suspend or revoke, any permit, license, certificate, approval, order, or similar authorization where the public entity or an employee of the public entity is authorized by enactment to determine whether or not such authorization should be issued, denied, suspended or revoked.

Notes of Decisions
Cited in 47 cases (6 in the last 5 years), 1968–2025 · leading case: Morris v. Cnty. of Marin, 559 P.2d 606 (Cal. 1977).
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Morris v. Cnty. of Marin, 559 P.2d 606 (Cal. 1977). · cites it 2× “As Professor Van Alstyne, one of the principal architects of, and commentators upon, the California Tort Claims Act, explains: "As far as public entity immunity is concerned, Government Code section 818.4 appears to be a continuation of prior law under which discretionary…”
Waschek v. Dep't of Motor Vehs., 97 Cal. Daily Op. Serv. 8900 (Cal. Ct. App. 1997). · cites it 3× “We hold that the State of California Department of Motor Vehicles (DMV) is not liable to a party injured by a licensed driver (Gov. Code, § 818.4) 1 when DMV had determined the driver was able “to safely operate a motor vehicle upon a highway.”
Harland v. State of California, 75 Cal. App. 3d 475 (Cal. Ct. App. 1977). · cites it 2× “No lawful basis has been shown for the exercise of such paternalistic powers over a citizen, in the absence of an adjudication of incompetency.”
HFH, LTD. v. Superior Court, 542 P.2d 237 (Cal. 1975). · cites it 2× “) We have recently held that an analogous tort immunity for the denial of a building permit (Gov. Code, § 818.4) constituted specific legislation qualifying the general rule that one may append a damage claim to a mandate action (Code Civ.”
Richards v. Dep't of Alcoholic Beverage Control, 2006 Cal. Daily Op. Serv. 3818 (Cal. Ct. App. 2006). · cites it 2× “2, subd (b)) therefore are immune from liability for any resulting injury.”
Kay v. City of Rancho Palos Verdes, 504 F.3d 803 (9th Cir. 2007). “Under a companion provision of California law, “[i]f judgment be given for the applicant, the applicant may recover the damages which the applicant has sustained .”
Thompson v. City of Lake Elsinore, 93 Cal. Daily Op. Serv. 6410 (Cal. Ct. App. 1993). · cites it 2× “Defendants asserted statutory immunity for their decisions in issuing or not issuing the requested permits, certificates or licenses (Gov. Code, §§ 818.4, 821.2). In response, owner asserted the specific statutory source of duty was City ordinance (i.”
Steed v. Dep't of Consum. Affairs, 204 Cal. App. 4th 112 (Cal. Ct. App. 2012). “8 [privilege for communications to aid evaluations of a veterinarian]), and defendants are public entities or employees who are immune from *118 liability (Gov. Code, §§818.4, 821.2 [licensing and permitting immunities], 815.”
Whaler's Vill. Club v. Califonia Coastal Comm'n, 173 Cal. App. 3d 240 (Cal. Ct. App. 1985). “6 Government Code section 818.4 already provides immunity to public entities for issuance or refusal to issue permits.”
Trinkle v. California State Lottery, 84 Cal. Rptr. 2d 496 (Cal. Ct. App. 1999). “The court sustained the demurrer without leave to amend on three grounds: (1) CSL is a governmental agency and not a “person” amenable to suit under the unfair competition law; (2) even if CSL were amenable to suit, damages are not available for past conduct; and (3) CSL’s…”
Walt Rankin & Assocs., Inc. v. City of Murrieta, 2000 Cal. Daily Op. Serv. 8824 (Cal. Ct. App. 2000). “” 17 Government Code section 818.4 provides: “A public entity is not liable for an injury caused by the issuance, denial, suspension or revocation of, or by the failure or refusal to issue, deny, suspend or revoke, any permit, license, certificate, approval, order, or similar…”
Patrick Media Grp., Inc. v. California Coastal Comm'n, 92 Cal. Daily Op. Serv. 7905 (Cal. Ct. App. 1992). “4 of the Government Code from an action in inverse *604 condemnation.”
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