California Codes

Cal. Government Code § 831.2 (2026)

✓ current as of May 2026

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Neither a public entity nor a public employee is liable for an injury caused by a natural condition of any unimproved public property, including but not limited to any natural condition of any lake, stream, bay, river or beach.

Notes of Decisions

Cited in 31 cases (3 in the last 5 years), 1967–2026 · leading case: Citizens for Odor Nuisance Abatement v. City of San Diego, 8 Cal. App. 5th 350 (Cal. Ct. App. 2017).

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Citizens for Odor Nuisance Abatement v. City of San Diego, 8 Cal. App. 5th 350 (Cal. Ct. App. 2017). · cites it 2× “2 Government Code section 831.2 provides, “[n]either a public entity nor a public employee is liable for an injury caused by a natural condition of any unimproved public property, including but not limited to any natural condition of any lake, stream, bay, river or beach.”

Rombalski v. City of Laguna Beach, 213 Cal. App. 3d 842 (Cal. Ct. App. 1989). · cites it 4× “I Government Code section 831.2 provides, "Neither a public entity nor a public employee is liable for an injury caused by a natural condition of any unimproved public property, including but not limited to any natural condition of any lake, stream, bay, river or beach.”

Milligan v. City of Laguna Beach, 670 P.2d 1121 (Cal. 1983). · cites it 2× “Government Code section 831.2 (further statutory references are to that code) immunizes public entities from tort liability for injuries resulting from a natural, though dangerous, condition of unimproved public property.”

Tessier v. City of Newport Beach, 219 Cal. App. 3d 310 (Cal. Ct. App. 1990). · cites it 3× “The City moved for summary judgment, asserting immunity from injuries caused by a natural condition (Gov. Code, § 831.2) and immunity based on Tessier’s engaging in a “hazardous recreational activity.”

Rendak v. State of California, 18 Cal. App. 3d 286 (Cal. Ct. App. 1971). · cites it 4× “) This statutory immunity has not as yet been interpreted by any court.”

Meddock v. Cnty. of Yolo CA3, 220 Cal. App. 4th 170 (Cal. Ct. App. 2013). “” (Gov. Code, § 831.2, hereafter section 831.”

City of Santa Cruz v. Superior Court, 198 Cal. App. 3d 999 (Cal. Ct. App. 1988). · cites it 2× “* The City of Santa Cruz (City) petitions for writ review under Code of Civil Procedure section 437c, subdivision (/), after the trial court denied City’s request for summary judgment based on natural condition immunity, Government Code section 831.2, and immunity of emergen…”

Knight v. City of Capitola, 92 Cal. Daily Op. Serv. 2354 (Cal. Ct. App. 1992). “We shall conclude, contrary to Knight’s position, that the city established without triable issue of material fact that it was entitled to natural-condition immunity under Government Code section 831.2. 4 Because section 831.”

Cabell v. State of California, 430 P.2d 34 (Cal. 1967). · cites it 2× “(Gov. Code, § 831.2.) [7] After plaintiff's accident the glass was replaced by a wooden panel window.”

Univ. of Alaska v. Shanti, 835 P.2d 1225 (Alaska 1992). “15 . We are not unmindful of the possibility that this consideration might discourage landowners from maintaining their property thus making land potentially more dangerous.”

Littleton v. State, 656 P.2d 1336 (Haw. 1982). “, Cal. Gov't Code § 831.2 (West 1963); N.J.”

Arroyo v. State of California, 95 Cal. Daily Op. Serv. 3276 (Cal. Ct. App. 1995). “Government Code section 831.2 protects public entities and employees from liability for injuries caused by natural conditions on unimproved public property.”

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