Cal. Codes » Government Code / TITLE 1. GENERAL / DIVISION 3.6. CLAIMS AND ACTIONS AGAINST PUBLIC ENTITIES AND PUBLIC EMPLOYEES / PART 4. ACTIONS AGAINST PUBLIC ENTITIES AND PUBLIC EMPLOYEES / CHAPTER 3. Actions Against Public Employees
California Codes

Cal. Government Code § 950.2 (2026)

✓ current as of May 2026
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Except as provided in Section 950.4, a cause of action against a public employee or former public employee for injury resulting from an act or omission in the scope of his employment as a public employee is barred if an action against the employing public entity for such injury is barred under Part 3 (commencing with Section 900) of this division or under Chapter 2 (commencing with Section 945) of Part 4 of this division. This section is applicable even though the public entity is immune from liability for the injury.

Notes of Decisions
Cited in 48 cases (13 in the last 5 years), 1966–2026 · leading case: Inman v. Anderson, 294 F. Supp. 3d 907 (N.D. Cal. 2018).
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Inman v. Anderson, 294 F. Supp. 3d 907 (N.D. Cal. 2018). “Further, California Government Code § 950.2 states that "a cause of action against a public employee or former public employee for injury resulting from an act or omission in the scope of his employment as a public employee is barred if an action against the employing public…”
Robinson v. Alameda Cnty., 875 F. Supp. 2d 1029 (N.D. Cal. 2012). “Plaintiffs Complaint is silent as to whether or not she filed a government claim pursuit to the California Government Claims Act (“CGCA”), codified at California Government Code section 950.2, prior to the filing of her Complaint.”
People ex rel. Harris v. Rizzo, 214 Cal. App. 4th 921 (Cal. Ct. App. 2013). “(Gov. Code, § 950.2.) This is so because a public entity is required to pay a judgment against its employee “for an injury arising out of an act or omission occurring within the scope of his or her employment as an employee of the public entity.”
D.K. Ex Rel. G.M. v. Solano Cnty. Off. of Educ., 667 F. Supp. 2d 1184 (E.D. Cal. 2009). “) Cal. Gov.Code § 950.2 states that in order to perfect a claim against a public employee for acts or omissions that occurred within the public employee’s scope of employment, a plaintiff must file a claim with the public entity employer.”
Briggs v. Lawrence, 91 Cal. Daily Op. Serv. 3885 (Cal. Ct. App. 1991). “) Accordingly the Legislature included in the Tort Claims Act what amounts to a requirement that (with exceptions not relevant here) one who sues a public employee on the basis of acts or omissions in the scope of the defendant’s employment have filed a claim against the…”
Okoro v. City of Oakland, 48 Cal. Rptr. 3d 260 (Cal. Ct. App. 2006). “) That limitations period applied to state causes of action against both the City and Olivas and Ausmus, who were, per the allegations, acting in the scope of their employment as public employees at the time of the incident.”
Harman v. Mono Gen. Hosp., 131 Cal. App. 3d 607 (Cal. Ct. App. 1982). “) It is also a condition precedent to a tort action against a public employee (Gov. Code, § 950.2; Williams v. Hovarth (1976) 16 Cal.”
Guzman v. Van Demark, 651 F. Supp. 1180 (C.D. Cal. 1987). · cites it 2× “In lawsuits against public employees, Cal.Govt.Code § 950.2 requires prospective plaintiffs to make a claim against the employing public entity before filing their complaint.”
Fisher v. Pickens, 90 Cal. Daily Op. Serv. 8678 (Cal. Ct. App. 1990). “In turn, Government Code section 950.2 prescribes that a cause against a public employee for injury resulting from an act or omission in the scope of his employment is barred if an action against the employing public entity is barred.”
Adler v. Los Angeles Unified Sch. Dist., 98 Cal. App. 3d 280 (Cal. Ct. App. 1979). “With an exception here immaterial, Government Code section 950.2 provides that a cause of action against a public employee for injury resulting from an act or omission within the scope of his or her employment is barred whenever an action against his or her employer for such…”
Bennett v. City of Los Angeles, 12 Cal. App. 3d 116 (Cal. Ct. App. 1970). “For this proposition petitioners rely on section 950.4 of the Government Code.”
Neal v. Gatlin, 35 Cal. App. 3d 871 (Cal. Ct. App. 1973). “1 Government Code section 950.2 provides in part: “.”
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