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14 California opinions name it 2 courts 1974–2025 5 in the last five years
The cases below were cited by California courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Loehr v. Ventura County Community College Districtgreen2 sentences2024In Loehr v. Ventura Community College Dist. (1983) 147 Cal.App.3d 1071, 1083 , the Court of Appeal explained that where necessary information is missing from a government claim, “the test of substantial compliance controls” and “the court must ask whether sufficient information is disclosed on the face of the filed claim ‘to reasonably enable the public entity to make an adequate investigation of the merits of the claim and to settle it without the expense of a lawsuit.’ ” (Ibid.) “The doctrine of substantial compliance, however, cannot cure total omission of an essential element from the clai 1989Under this test, the court must ask whether sufficient information is disclosed on the face of the filed claim ‘to reasonably enable the public entity to make an adequate investigation of the merits of the claim and to settle it without the expense of a lawsuit.’ [Citation.]” (Loehr v. Ventura County Community College Dist. (1983) 147 Cal.App.3d 1071, 1082-1083 [ 195 Cal.Rptr. 576 ].) Several cases have barred a cause of action because it was based on an entirely different factual theory from that alleged in the claim. | 2 | 3 |
City of San Jose v. Superior Courtgreen2 sentences2024Appellant cites no authority that this equitable doctrine applies in the context of a party’s failure to file a timely claim under the Government Claim Act. 15 Angeles (1974) 11 Cal.3d 113, 123 (Minsky) for the proposition that, “[s]o long as the policies of the claims statutes are effectuated, they should be given a liberal construction to permit full adjudication on the merits.”9 Appellant relies on City of San Jose v. Superior Court (1974) 12 Cal.3d 447 (San Jose), in asking that we pose the question: “Is there sufficient information disclosed on the face of the filed claim to reasonably en 1986Under this test, the court must ask whether sufficient information is disclosed on the face of the filed claim ‘to reasonably enable the public entity to make an adequate investigation of the merits of the claim and to settle it without the expense of a lawsuit.’ (City of San Jose v. Superior Court (1974) 12 Cal. 3d 447, 456 [ 115 Cal.Rptr. 797 , 525 P.2d 701 , 76 A.L.R.3d 1223 ].)” (See also State of California ex rel. | 2 | 3 |
Hall v. City of Los Angelesgreen2 sentences1980Under this test, the court must ask whether sufficient information is disclosed on the face of the filed claim “to reasonably enable the public entity to make an adequate investigation of the merits of the claim and to settle it without the expense of a lawsuit.” (Id., at p. 456.) However, it has repeatedly been held that “‘[substantial compliance cannot be predicated upon no compliance.’” (Id., quoting Hall v. City of Los Angeles (1941) 19 Cal.2d 198, 202 [ 120 P.2d 13 ]; Johnson v. City of Oakland (1961) 188 Cal.App.2d 181, 183 [ 10 Cal.Rptr. 409 ].) Thus, widow’s failure to allege that she 1980Under this test, the court must ask whether sufficient information is disclosed on the face of the filed claim “to reasonably enable the public entity to make an adequate investigation of the merits of the claim and to settle it without the expense of a lawsuit.” (Id., at p. 456.) However, it has repeatedly been held that “‘[substantial compliance cannot be predicated upon no compliance.’” (Id., quoting Hall v. City of Los Angeles (1941) 19 Cal.2d 198, 202 [ 120 P.2d 13 ]; Johnson v. City of Oakland (1961) 188 Cal.App.2d 181, 183 [ 10 Cal.Rptr. 409 ].) Thus, widow’s failure to allege that she | 1 | 2 |
Minsky v. City of Los Angelesgreen1 sentence2024Appellant cites no authority that this equitable doctrine applies in the context of a party’s failure to file a timely claim under the Government Claim Act. 15 Angeles (1974) 11 Cal.3d 113, 123 (Minsky) for the proposition that, “[s]o long as the policies of the claims statutes are effectuated, they should be given a liberal construction to permit full adjudication on the merits.”9 Appellant relies on City of San Jose v. Superior Court (1974) 12 Cal.3d 447 (San Jose), in asking that we pose the question: “Is there sufficient information disclosed on the face of the filed claim to reasonably en | 1 | 1 |
Mai Chi Nguyen v. Los Angeles County Harbor/UCLA Medical Centergreen1 sentence2023“Where a claimant has attempted to comply with the claim requirements but the claim is deficient in some way, the doctrine of substantial compliance may validate the claim ‘if it substantially complies with all of the statutory requirements . . . even though it is technically deficient in one or more particulars.’ ” (Connelly v. County of Fresno (2006) 146 Cal.App.4th 29, 38 .) “The test for substantial compliance is whether the face of the filed claim discloses sufficient information to enable the public entity to make an adequate investigation of the claim’s merits and settle it without the | 1 | 1 |
Nelson v. County of Los Angelesgreen1 sentence2023Because the Act requires (1) presentation of a claim that (2) includes the claimant’s name, they did not comply with all of the Act’s requirements. 6 (See § 910 [claim presented must include claimant’s name]; Nelson v. County of Los Angeles (2003) 113 Cal.App.4th 783, 797 (Nelson) [“the statutory requirements have not been met by a person who has not filed a claim.”].) Having failed to comply with the threshold requirement of filing or being named in a claim at all, appellants cannot demonstrate that their claim is substantially compliant. | 1 | 1 |
Pacific Telephone & Telegraph Co. v. County of Riversidegreen2 sentences1994Co. v. County of Riverside (1980) 106 Cal.App.3d 183, 188 [ 165 Cal.Rptr. 29 ].) Arguably, had plaintiff’s letters been sent to the appropriate agency for the handling of claims (and, had they been transmitted to the persons designated by the statute, they presumably would have been) the information supplied would have enabled the agency to make an adequate investigation. 1994Co. v. County of Riverside (1980) 106 Cal.App.3d 183, 188 [ 165 Cal.Rptr. 29 ].) Arguably, had plaintiff’s letters been sent to the appropriate agency for the handling of claims (and, had they been transmitted to the persons designated by the statute, they presumably would have been) the information supplied would have enabled the agency to make an adequate investigation. | 1 | 1 |
Dhuyvetter v. City of Fresnogreen2 sentences1987(City of San Jose v. Superior Court, supra, 12 Cal. 3d at pp. 456-457.) The test for the sufficiency of a particular claim is set forth in City of San Jose v. Superior Court, supra, at pages 456-457: “[W]e conclude that to gauge the sufficiency of a particular claim, two tests shall be applied: Is there some compliance with all of the statutory requirements; and, if so, is this compliance sufficient to constitute substantial compliance?” (Italics in original.) (See also Dhuyvetter v. City of Fresno (1980) 110 Cal.App.3d 659, 664-665 [ 168 Cal.Rptr. 61 ].) Where there has been an attempt to com 1987(City of San Jose v. Superior Court, supra, 12 Cal. 3d at pp. 456-457.) The test for the sufficiency of a particular claim is set forth in City of San Jose v. Superior Court, supra, at pages 456-457: “[W]e conclude that to gauge the sufficiency of a particular claim, two tests shall be applied: Is there some compliance with all of the statutory requirements; and, if so, is this compliance sufficient to constitute substantial compliance?” (Italics in original.) (See also Dhuyvetter v. City of Fresno (1980) 110 Cal.App.3d 659, 664-665 [ 168 Cal.Rptr. 61 ].) Where there has been an attempt to com | 1 | 1 |
State Ex Rel. Department of Transportation v. Superior Courtgreen2 sentences1986Dept, of Transportation v. Superior Court (1984) 159 Cal.App.3d 331, 336-338 [ 205 Cal.Rptr. 518 ].) Stated another way, the claimant’s judicial pleadings are limited to bases for recovery “fairly reflected in the written claim.” (State of California ex rel. 1986Dept, of Transportation v. Superior Court (1984) 159 Cal.App.3d 331, 336-338 [ 205 Cal.Rptr. 518 ].) Stated another way, the claimant’s judicial pleadings are limited to bases for recovery “fairly reflected in the written claim.” (State of California ex rel. | 1 | 1 |
Johnson v. City of Oaklandgreen2 sentences1980Under this test, the court must ask whether sufficient information is disclosed on the face of the filed claim “to reasonably enable the public entity to make an adequate investigation of the merits of the claim and to settle it without the expense of a lawsuit.” (Id., at p. 456.) However, it has repeatedly been held that “‘[substantial compliance cannot be predicated upon no compliance.’” (Id., quoting Hall v. City of Los Angeles (1941) 19 Cal.2d 198, 202 [ 120 P.2d 13 ]; Johnson v. City of Oakland (1961) 188 Cal.App.2d 181, 183 [ 10 Cal.Rptr. 409 ].) Thus, widow’s failure to allege that she 1980Under this test, the court must ask whether sufficient information is disclosed on the face of the filed claim “to reasonably enable the public entity to make an adequate investigation of the merits of the claim and to settle it without the expense of a lawsuit.” (Id., at p. 456.) However, it has repeatedly been held that “‘[substantial compliance cannot be predicated upon no compliance.’” (Id., quoting Hall v. City of Los Angeles (1941) 19 Cal.2d 198, 202 [ 120 P.2d 13 ]; Johnson v. City of Oakland (1961) 188 Cal.App.2d 181, 183 [ 10 Cal.Rptr. 409 ].) Thus, widow’s failure to allege that she | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in California. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Connelly v. County of Fresno
green
2 sentences2025The doctrine of substantial compliance, however, ‘cannot cure total omission of an essential element from the claim or remedy a plaintiff's failure to comply meaningfully with the statute.’ [Citation.] The test for substantial compliance is whether the face of the filed claim discloses sufficient information to enable the public entity to make an adequate investigation of the claim’s merits and settle it without the expense of litigation.” (Connelly v. County of Fresno (2006) 146 Cal.App.4th 29, 38 .) According to plaintiff, the October 13, 2022 claim form that she presented to the District me 2024Substantial compliance doctrine “Where a claimant has attempted to comply with the claim requirements but the claim is deficient in some way, the doctrine of substantial compliance may validate the claim ‘if it substantially complies with all of the statutory requirements . . . even though it is technically deficient in one or more particulars.’ ” (Connelly v. County of Fresno (2006) 146 Cal.App.4th 29, 38 .) “The doctrine of substantial compliance, however, ‘cannot cure total omission of an essential element from the claim or remedy a plaintiff’s failure to comply meaningfully with the statut | 3 | 2023–2025 |
Stockett v. Association of California Water Agencies Joint Powers Insurance Authority
green
2 sentences2025The doctrine of substantial compliance, however, ‘cannot cure total omission of an essential element from the claim or remedy a plaintiff's failure to comply meaningfully with the statute.’ [Citation.] The test for substantial compliance is whether the face of the filed claim discloses sufficient information to enable the public entity to make an adequate investigation of the claim’s merits and settle it without the expense of litigation.” (Connelly v. County of Fresno (2006) 146 Cal.App.4th 29, 38 .) According to plaintiff, the October 13, 2022 claim form that she presented to the District me 2025The doctrine of substantial compliance, however, ‘cannot cure total omission of an essential element from the claim or remedy a plaintiff's failure to comply meaningfully with the statute.’ [Citation.] The test for substantial compliance is whether the face of the filed claim discloses sufficient information to enable the public entity to make an adequate investigation of the claim’s merits and settle it without the expense of litigation.” (Connelly v. County of Fresno (2006) 146 Cal.App.4th 29, 38 .) According to plaintiff, the October 13, 2022 claim form that she presented to the District me | 1 | 2025–2025 |
Connelly v. State of California
green
2 sentences1989In Connelly v. State of California (1970) 3 Cal.App.3d 744 [ 84 Cal.Rptr. 257 ], the plaintiff, relying on information from a state agency, prepared his boat docks to withstand an expected rise in the level of the Sacramento River. 1989In Connelly v. State of California (1970) 3 Cal.App.3d 744 [ 84 Cal.Rptr. 257 ], the plaintiff, relying on information from a state agency, prepared his boat docks to withstand an expected rise in the level of the Sacramento River. | 1 | 1989–1989 |
Tyus v. City of Los Angeles
green
2 sentences1983(Hall v. City of Los Angeles (1941) 19 Cal.2d 198 [ 120 P.2d 13 ]; Tyus v. City of Los Angeles (1977) 74 Cal.App.3d 667 [ 141 Cal.Rptr. 630 ]; Shelton v. Superior Court (1976) 56 Cal.App.3d 66 [ 128 Cal.Rptr. 454 ].) Even a cursory reading of plaintiff’s May 12th letter demonstrates that it fails to satisfy the test of substantial compliance and thus cannot be considered a claim for damages within the meaning of Government Code section 945.4. 1983(Hall v. City of Los Angeles (1941) 19 Cal.2d 198 [ 120 P.2d 13 ]; Tyus v. City of Los Angeles (1977) 74 Cal.App.3d 667 [ 141 Cal.Rptr. 630 ]; Shelton v. Superior Court (1976) 56 Cal.App.3d 66 [ 128 Cal.Rptr. 454 ].) Even a cursory reading of plaintiff’s May 12th letter demonstrates that it fails to satisfy the test of substantial compliance and thus cannot be considered a claim for damages within the meaning of Government Code section 945.4. | 1 | 1983–1983 |
Shelton v. Superior Court
green
2 sentences1983(Hall v. City of Los Angeles (1941) 19 Cal.2d 198 [ 120 P.2d 13 ]; Tyus v. City of Los Angeles (1977) 74 Cal.App.3d 667 [ 141 Cal.Rptr. 630 ]; Shelton v. Superior Court (1976) 56 Cal.App.3d 66 [ 128 Cal.Rptr. 454 ].) Even a cursory reading of plaintiff’s May 12th letter demonstrates that it fails to satisfy the test of substantial compliance and thus cannot be considered a claim for damages within the meaning of Government Code section 945.4. 1983(Hall v. City of Los Angeles (1941) 19 Cal.2d 198 [ 120 P.2d 13 ]; Tyus v. City of Los Angeles (1977) 74 Cal.App.3d 667 [ 141 Cal.Rptr. 630 ]; Shelton v. Superior Court (1976) 56 Cal.App.3d 66 [ 128 Cal.Rptr. 454 ].) Even a cursory reading of plaintiff’s May 12th letter demonstrates that it fails to satisfy the test of substantial compliance and thus cannot be considered a claim for damages within the meaning of Government Code section 945.4. | 1 | 1983–1983 |
Midstate Theatres, Inc. v. Board of Supervisors
green
2 sentences1980(Midstate Theatres, Inc. v. Board of Supervisors (1975) 46 Cal.App.3d 204 [ 119 Cal.Rptr. 894 ].) Plaintiffs have failed to plead any excuse for failing to exhaust their administrative remedies and they have not presented any excuse to this court. 6 The court stated the test of substantial compliance as follows: “Is there sufficient information disclosed on the face of the filed claim to reasonably enable the public entity to make an adequate investigation of the merits of the claim and to settle it without the expense of a lawsuit?” (City of San Jose v. Superior Court, supra, at p. 456.) 7 It 1980(Midstate Theatres, Inc. v. Board of Supervisors (1975) 46 Cal.App.3d 204 [ 119 Cal.Rptr. 894 ].) Plaintiffs have failed to plead any excuse for failing to exhaust their administrative remedies and they have not presented any excuse to this court. 6 The court stated the test of substantial compliance as follows: “Is there sufficient information disclosed on the face of the filed claim to reasonably enable the public entity to make an adequate investigation of the merits of the claim and to settle it without the expense of a lawsuit?” (City of San Jose v. Superior Court, supra, at p. 456.) 7 It | 1 | 1980–1980 |
Sandstoe v. Atchison, Topeka & Santa Fe Railway Co.
green
2 sentences1974Co. (1938) 28 Cal. App.2d 215 [ 82 P.2d 216 ] (verified by father instead of claimant minor child).) In these cases the test of "substantial compliance" controls: Is there sufficient information disclosed on the face of the filed claim to reasonably enable the public entity to make an adequate investigation of the merits of the claim and to settle it without the expense of a lawsuit? 1974Co. (1938) 28 Cal. App.2d 215 [ 82 P.2d 216 ] (verified by father instead of claimant minor child).) In these cases the test of "substantial compliance" controls: Is there sufficient information disclosed on the face of the filed claim to reasonably enable the public entity to make an adequate investigation of the merits of the claim and to settle it without the expense of a lawsuit? | 1 | 1974–1974 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.