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 § 950.4 (2026)

✓ current as of May 2026
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A cause of action against a public employee or former public employee is not barred by Section 950.2 if the plaintiff pleads and proves that he did not know or have reason to know, within the period for the presentation of a claim to the employing public entity as a condition to maintaining an action for such injury against the employing public entity, as that period is prescribed by Section 911.2 or by such other claims procedure as may be applicable, that the injury was caused by an act or omission of the public entity or by an act or omission of an employee of the public entity in the scope of his employment as a public employee.

Notes of Decisions
Cited in 9 cases (4 in the last 5 years), 1976–2025 · leading case: Leake v. Wu, 64 Cal. App. 3d 668 (Cal. Ct. App. 1976).
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Leake v. Wu, 64 Cal. App. 3d 668 (Cal. Ct. App. 1976). · cites it 2× “Government Code section 950.4 provides: “A cause of action against a public employee or former public employee is not barred by Section 950.”
Moore v. Morhar, 65 Cal. App. 3d 896 (Cal. Ct. App. 1977). “Also, the basis of the claim for relief—Government Code section 950.4, is clear. 7 As the construction of section 950.”
Black v. Cnty. of Los Angeles, 55 Cal. App. 3d 920 (Cal. Ct. App. 1976). “” Government Code section 950.4 reads: “A cause of action against a public employee or former public employee is not barred by Section *929 950.”
(PC) Price v. Pacheco (E.D. Cal. 2024). · cites it 2× “4, Plaintiffs assert that the claims 24 presentation requirement is inapplicable in this case because Plaintiffs had no reason to suspect 25 the involvement of government employees until July 2022 when the family learned the true cause 26 of Mr.”
Barroca v. Hayward Area Rec. & Parks Dist. (N.D. Cal. 2025). · cites it 2× “California Government Code § 950.4 24 There is a narrow exception provided by Cal.”
Gomez v. Madden (S.D. Cal. 2020). “” Cal. Gov. Code § 950.4 . 20 However, Plaintiff filed his initial complaint on September 12, 2016, within the one-year 21 period to apply to present an untimely claim.”
Hamilton v. California Dep't of Corr. Rehab. (S.D. Cal. 2021). “” Cal. Gov. Code § 950.4 . Plaintiff’s Complaint, however, demonstrates that he 23 knew about the relevant facts on, if not before, November 10, 2017, when he submitted his 24 initial grievance with RJD.”
Crawley (E.D. Cal. 2025). “” Cal. Gov. Code § 950.4 . In other words, a plaintiff may maintain a cause 20 of action in court against a public employee whose identity he did not know “provided []he can 21 plead and prove .”
Watson v. Albin, 551 F. Supp. 2d 954 (N.D. Cal. 2008). “The plaintiffs invoke California Government Code section 950.4, a statutory exception to section 950.”
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