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8 California opinions name it 2 courts 2013–2026 6 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 |
|---|---|---|
Santos v. L. A. Unified Sch. Dist.green1 sentence2026(See Santos v. Los Angeles Unified School Dist. (2017) 17 Cal.App.5th 1065, 1077 [school district estopped from arguing GCA claim was misaddressed because district-police lieutenant directed plaintiff how to file claim].) Third, the lack of an official rejection of Tran’s claim by the district’s board is immaterial. | 1 | 1 |
C.A. v. William S. Hart Union High School Districtgreen2 sentences2025(West Contra Costa Unified, at p. 1260; O.B., supra, ___ Cal.App.5th at p. ___ [2025 Cal. App. Lexis 540, at pp. *12–*13]; see C.A. v. William S. Hart Union High School Dist. (2012) 53 Cal.4th 861, 865 [school district may be found vicariously liable for the negligence of supervisory or administrative personnel who knew or should have known of an employee’s propensities for sexual harassment and nevertheless hired, retained, and inadequately supervised the employee].) Beyond the GCA statutes, the West Contra Costa Unified court found instructive the Supreme Court’s analysis in Quigley, supra, 2025(West Contra Costa Unified, at p. 1260; O.B., supra, ___ Cal.App.5th at p. ___ [2025 Cal. App. Lexis 540, at pp. *12–*13]; see C.A. v. William S. Hart Union High School Dist. (2012) 53 Cal.4th 861, 865 [school district may be found vicariously liable for the negligence of supervisory or administrative personnel who knew or should have known of an employee’s propensities for sexual harassment and nevertheless hired, retained, and inadequately supervised the employee].) Beyond the GCA statutes, the West Contra Costa Unified court found instructive the Supreme Court’s analysis in Quigley, supra, | 1 | 1 |
Quigley v. Garden Valley Fire Protection Dist.green2 sentences2025(West Contra Costa Unified, at p. 1260; O.B., supra, ___ Cal.App.5th at p. ___ [2025 Cal. App. Lexis 540, at pp. *12–*13]; see C.A. v. William S. Hart Union High School Dist. (2012) 53 Cal.4th 861, 865 [school district may be found vicariously liable for the negligence of supervisory or administrative personnel who knew or should have known of an employee’s propensities for sexual harassment and nevertheless hired, retained, and inadequately supervised the employee].) Beyond the GCA statutes, the West Contra Costa Unified court found instructive the Supreme Court’s analysis in Quigley, supra, 2025(West Contra Costa Unified, at p. 1260; O.B., supra, ___ Cal.App.5th at p. ___ [2025 Cal. App. Lexis 540, at pp. *12–*13]; see C.A. v. William S. Hart Union High School Dist. (2012) 53 Cal.4th 861, 865 [school district may be found vicariously liable for the negligence of supervisory or administrative personnel who knew or should have known of an employee’s propensities for sexual harassment and nevertheless hired, retained, and inadequately supervised the employee].) Beyond the GCA statutes, the West Contra Costa Unified court found instructive the Supreme Court’s analysis in Quigley, supra, | 1 | 1 |
Shirk v. Vista Unified School Districtred1 sentence2025(See Shirk v. Vista Unified School Dist. (2007) 42 Cal.4th 201, 207, 209 (Shirk) [under Gov. | 1 | 1 |
West Contra Costa Unified School Dist. v. Super. Ct.green2 sentences2025(West Contra Costa Unified, at p. 1260; O.B., supra, ___ Cal.App.5th at p. ___ [2025 Cal. App. Lexis 540, at pp. *12–*13]; see C.A. v. William S. Hart Union High School Dist. (2012) 53 Cal.4th 861, 865 [school district may be found vicariously liable for the negligence of supervisory or administrative personnel who knew or should have known of an employee’s propensities for sexual harassment and nevertheless hired, retained, and inadequately supervised the employee].) Beyond the GCA statutes, the West Contra Costa Unified court found instructive the Supreme Court’s analysis in Quigley, supra, 2025(West Contra Costa Unified, at p. 1260; O.B., supra, ___ Cal.App.5th at p. ___ [2025 Cal. App. Lexis 540, at pp. *12–*13]; see C.A. v. William S. Hart Union High School Dist. (2012) 53 Cal.4th 861, 865 [school district may be found vicariously liable for the negligence of supervisory or administrative personnel who knew or should have known of an employee’s propensities for sexual harassment and nevertheless hired, retained, and inadequately supervised the employee].) Beyond the GCA statutes, the West Contra Costa Unified court found instructive the Supreme Court’s analysis in Quigley, supra, | 1 | 1 |
Stockett v. Association of California Water Agencies Joint Powers Insurance Authoritygreen2 sentences2025Authority (2004) 34 Cal.4th 441, 447 (Stockett).) Such variances are fatal “because they subvert the purpose of the [GCA], which is intended to give the public entity an opportunity to investigate and evaluate its potential liability and, where appropriate, avoid litigation by settling meritorious claims.” (Hernandez, at p. 1232.) Nevertheless, because a GCA 16. claim need not identify each particular act or omission that is later proven to have caused the injury, a complaint may elaborate or add further detail to a claim so long as the claim is predicated on the same fundamental acts or omiss 2025Authority (2004) 34 Cal.4th 441, 447 (Stockett).) Such variances are fatal “because they subvert the purpose of the [GCA], which is intended to give the public entity an opportunity to investigate and evaluate its potential liability and, where appropriate, avoid litigation by settling meritorious claims.” (Hernandez, at p. 1232.) Nevertheless, because a GCA 16. claim need not identify each particular act or omission that is later proven to have caused the injury, a complaint may elaborate or add further detail to a claim so long as the claim is predicated on the same fundamental acts or omiss | 1 | 1 |
Snipes v. City of Bakersfieldred1 sentence2022(See § 946.4.) 3 When the GCA applies to a claim, “[a]s a general rule, a plaintiff must present a public entity with a timely written claim for damages before filing suit against it.” (J.M. v. Huntington Beach Union High School Dist. (2017) 2 Cal.5th 648, 652 .) If 4 barrier for Williams to file a lawsuit on FEHA claims (Snipes v. City of Bakersfield (1983) 145 Cal.App.3d 861, 869-870 [FEHA administrative complaint procedures and GCA presentation requirements serve similar functions]), but compliance with the additional GCA procedures would apply to viable state common law claims not otherwis | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in California. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Hernandez v. City of Stockton
green
2 sentences2025(Hernandez v. City of Stockton (2023) 90 Cal.App.5th 1222 , 1232.) This often occurs when a complaint bases liability on acts committed at different times or by different people from the acts identified in a GCA claim. 2025(Hernandez v. City of Stockton (2023) 90 Cal.App.5th 1222 , 1232.) This often occurs when a complaint bases liability on acts committed at different times or by different people from the acts identified in a GCA claim. | 1 | 2025–2025 |
J.M. v. Huntington Beach Union High School Dist.
green
1 sentence2022(See § 946.4.) 3 When the GCA applies to a claim, “[a]s a general rule, a plaintiff must present a public entity with a timely written claim for damages before filing suit against it.” (J.M. v. Huntington Beach Union High School Dist. (2017) 2 Cal.5th 648, 652 .) If 4 barrier for Williams to file a lawsuit on FEHA claims (Snipes v. City of Bakersfield (1983) 145 Cal.App.3d 861, 869-870 [FEHA administrative complaint procedures and GCA presentation requirements serve similar functions]), but compliance with the additional GCA procedures would apply to viable state common law claims not otherwis | 1 | 2022–2022 |
Dominguez v. City of Alhambra
green
2 sentences2021“Suits against a public entity are governed by the specific statute of limitations provided in the Government Code, rather than the statute of limitations which applies to private defendants.” (Dominguez v. City of Alhambra (1981) 118 Cal.App.3d 237, 244 .) 8 With some exceptions not applicable here, the GCA provides that a lawsuit against a public entity must be filed no later than six months after the entity rejects the plaintiff’s GCA claim. 2021“Suits against a public entity are governed by the specific statute of limitations provided in the Government Code, rather than the statute of limitations which applies to private defendants.” (Dominguez v. City of Alhambra (1981) 118 Cal.App.3d 237, 244 .) 8 With some exceptions not applicable here, the GCA provides that a lawsuit against a public entity must be filed no later than six months after the entity rejects the plaintiff’s GCA claim. | 1 | 2021–2021 |
Kemmerer v. County of Fresno
red
2 sentences2019Program for Employees (SIPE) (2007) 157 Cal.App.4th 1056 , 1061, 69 Cal.Rptr.3d 176 ["Government tort immunity is jurisdictional and may be raised for the first time on appeal."]; Inland Empire Health Plan v. Superior Court (2003) 108 Cal.App.4th 588 , 592, 133 Cal.Rptr.2d 735 ["[G]overnmental immunity from liability is a jurisdictional matter that can be raised for the first time on appellate review."]; Hata , supra , 31 Cal.App.4th at p. 1795 , 37 Cal.Rptr.2d 630 ["[G]overnmental tort immunity ... is a jurisdictional issue that may be raised at any time, even for the first time on appeal."]; 2019Program for Employees (SIPE) (2007) 157 Cal.App.4th 1056 , 1061, 69 Cal.Rptr.3d 176 ["Government tort immunity is jurisdictional and may be raised for the first time on appeal."]; Inland Empire Health Plan v. Superior Court (2003) 108 Cal.App.4th 588 , 592, 133 Cal.Rptr.2d 735 ["[G]overnmental immunity from liability is a jurisdictional matter that can be raised for the first time on appellate review."]; Hata , supra , 31 Cal.App.4th at p. 1795 , 37 Cal.Rptr.2d 630 ["[G]overnmental tort immunity ... is a jurisdictional issue that may be raised at any time, even for the first time on appeal."]; | 1 | 2019–2019 |
Inland Empire Health Plan v. Superior Court
green
2 sentences2019Program for Employees (SIPE) (2007) 157 Cal.App.4th 1056 , 1061, 69 Cal.Rptr.3d 176 ["Government tort immunity is jurisdictional and may be raised for the first time on appeal."]; Inland Empire Health Plan v. Superior Court (2003) 108 Cal.App.4th 588 , 592, 133 Cal.Rptr.2d 735 ["[G]overnmental immunity from liability is a jurisdictional matter that can be raised for the first time on appellate review."]; Hata , supra , 31 Cal.App.4th at p. 1795 , 37 Cal.Rptr.2d 630 ["[G]overnmental tort immunity ... is a jurisdictional issue that may be raised at any time, even for the first time on appeal."]; 2019Program for Employees (SIPE) (2007) 157 Cal.App.4th 1056 , 1061, 69 Cal.Rptr.3d 176 ["Government tort immunity is jurisdictional and may be raised for the first time on appeal."]; Inland Empire Health Plan v. Superior Court (2003) 108 Cal.App.4th 588 , 592, 133 Cal.Rptr.2d 735 ["[G]overnmental immunity from liability is a jurisdictional matter that can be raised for the first time on appellate review."]; Hata , supra , 31 Cal.App.4th at p. 1795 , 37 Cal.Rptr.2d 630 ["[G]overnmental tort immunity ... is a jurisdictional issue that may be raised at any time, even for the first time on appeal."]; | 1 | 2019–2019 |
Richardson-Tunnell v. Schools Insurance Program for Employees
green
2 sentences2019Program for Employees (SIPE) (2007) 157 Cal.App.4th 1056 , 1061, 69 Cal.Rptr.3d 176 ["Government tort immunity is jurisdictional and may be raised for the first time on appeal."]; Inland Empire Health Plan v. Superior Court (2003) 108 Cal.App.4th 588 , 592, 133 Cal.Rptr.2d 735 ["[G]overnmental immunity from liability is a jurisdictional matter that can be raised for the first time on appellate review."]; Hata , supra , 31 Cal.App.4th at p. 1795 , 37 Cal.Rptr.2d 630 ["[G]overnmental tort immunity ... is a jurisdictional issue that may be raised at any time, even for the first time on appeal."]; 2019Program for Employees (SIPE) (2007) 157 Cal.App.4th 1056 , 1061, 69 Cal.Rptr.3d 176 ["Government tort immunity is jurisdictional and may be raised for the first time on appeal."]; Inland Empire Health Plan v. Superior Court (2003) 108 Cal.App.4th 588 , 592, 133 Cal.Rptr.2d 735 ["[G]overnmental immunity from liability is a jurisdictional matter that can be raised for the first time on appellate review."]; Hata , supra , 31 Cal.App.4th at p. 1795 , 37 Cal.Rptr.2d 630 ["[G]overnmental tort immunity ... is a jurisdictional issue that may be raised at any time, even for the first time on appeal."]; | 1 | 2019–2019 |
Hata v. Los Angeles County Harbor/UCLA Medical Center
red
2 sentences2019Program for Employees (SIPE) (2007) 157 Cal.App.4th 1056 , 1061, 69 Cal.Rptr.3d 176 ["Government tort immunity is jurisdictional and may be raised for the first time on appeal."]; Inland Empire Health Plan v. Superior Court (2003) 108 Cal.App.4th 588 , 592, 133 Cal.Rptr.2d 735 ["[G]overnmental immunity from liability is a jurisdictional matter that can be raised for the first time on appellate review."]; Hata , supra , 31 Cal.App.4th at p. 1795 , 37 Cal.Rptr.2d 630 ["[G]overnmental tort immunity ... is a jurisdictional issue that may be raised at any time, even for the first time on appeal."]; 2019Program for Employees (SIPE) (2007) 157 Cal.App.4th 1056 , 1061, 69 Cal.Rptr.3d 176 ["Government tort immunity is jurisdictional and may be raised for the first time on appeal."]; Inland Empire Health Plan v. Superior Court (2003) 108 Cal.App.4th 588 , 592, 133 Cal.Rptr.2d 735 ["[G]overnmental immunity from liability is a jurisdictional matter that can be raised for the first time on appellate review."]; Hata , supra , 31 Cal.App.4th at p. 1795 , 37 Cal.Rptr.2d 630 ["[G]overnmental tort immunity ... is a jurisdictional issue that may be raised at any time, even for the first time on appeal."]; | 1 | 2019–2019 |
Buford v. State of California
green
2 sentences2019Program for Employees (SIPE) (2007) 157 Cal.App.4th 1056 , 1061, 69 Cal.Rptr.3d 176 ["Government tort immunity is jurisdictional and may be raised for the first time on appeal."]; Inland Empire Health Plan v. Superior Court (2003) 108 Cal.App.4th 588 , 592, 133 Cal.Rptr.2d 735 ["[G]overnmental immunity from liability is a jurisdictional matter that can be raised for the first time on appellate review."]; Hata , supra , 31 Cal.App.4th at p. 1795 , 37 Cal.Rptr.2d 630 ["[G]overnmental tort immunity ... is a jurisdictional issue that may be raised at any time, even for the first time on appeal."]; 2019Program for Employees (SIPE) (2007) 157 Cal.App.4th 1056 , 1061, 69 Cal.Rptr.3d 176 ["Government tort immunity is jurisdictional and may be raised for the first time on appeal."]; Inland Empire Health Plan v. Superior Court (2003) 108 Cal.App.4th 588 , 592, 133 Cal.Rptr.2d 735 ["[G]overnmental immunity from liability is a jurisdictional matter that can be raised for the first time on appellate review."]; Hata , supra , 31 Cal.App.4th at p. 1795 , 37 Cal.Rptr.2d 630 ["[G]overnmental tort immunity ... is a jurisdictional issue that may be raised at any time, even for the first time on appeal."]; | 1 | 2019–2019 |
Hooper v. City of Chula Vista
yellow
2 sentences2019Program for Employees (SIPE) (2007) 157 Cal.App.4th 1056 , 1061, 69 Cal.Rptr.3d 176 ["Government tort immunity is jurisdictional and may be raised for the first time on appeal."]; Inland Empire Health Plan v. Superior Court (2003) 108 Cal.App.4th 588 , 592, 133 Cal.Rptr.2d 735 ["[G]overnmental immunity from liability is a jurisdictional matter that can be raised for the first time on appellate review."]; Hata , supra , 31 Cal.App.4th at p. 1795 , 37 Cal.Rptr.2d 630 ["[G]overnmental tort immunity ... is a jurisdictional issue that may be raised at any time, even for the first time on appeal."]; 2019Program for Employees (SIPE) (2007) 157 Cal.App.4th 1056 , 1061, 69 Cal.Rptr.3d 176 ["Government tort immunity is jurisdictional and may be raised for the first time on appeal."]; Inland Empire Health Plan v. Superior Court (2003) 108 Cal.App.4th 588 , 592, 133 Cal.Rptr.2d 735 ["[G]overnmental immunity from liability is a jurisdictional matter that can be raised for the first time on appellate review."]; Hata , supra , 31 Cal.App.4th at p. 1795 , 37 Cal.Rptr.2d 630 ["[G]overnmental tort immunity ... is a jurisdictional issue that may be raised at any time, even for the first time on appeal."]; | 1 | 2019–2019 |
State of California v. Superior Court
green
2 sentences2019Program for Employees (SIPE) (2007) 157 Cal.App.4th 1056 , 1061, 69 Cal.Rptr.3d 176 ["Government tort immunity is jurisdictional and may be raised for the first time on appeal."]; Inland Empire Health Plan v. Superior Court (2003) 108 Cal.App.4th 588 , 592, 133 Cal.Rptr.2d 735 ["[G]overnmental immunity from liability is a jurisdictional matter that can be raised for the first time on appellate review."]; Hata , supra , 31 Cal.App.4th at p. 1795 , 37 Cal.Rptr.2d 630 ["[G]overnmental tort immunity ... is a jurisdictional issue that may be raised at any time, even for the first time on appeal."]; 2019Program for Employees (SIPE) (2007) 157 Cal.App.4th 1056 , 1061, 69 Cal.Rptr.3d 176 ["Government tort immunity is jurisdictional and may be raised for the first time on appeal."]; Inland Empire Health Plan v. Superior Court (2003) 108 Cal.App.4th 588 , 592, 133 Cal.Rptr.2d 735 ["[G]overnmental immunity from liability is a jurisdictional matter that can be raised for the first time on appellate review."]; Hata , supra , 31 Cal.App.4th at p. 1795 , 37 Cal.Rptr.2d 630 ["[G]overnmental tort immunity ... is a jurisdictional issue that may be raised at any time, even for the first time on appeal."]; | 1 | 2019–2019 |
Munoz v. State of California
green
2 sentences2013(See Munoz v. State of California, supra, 33 Cal.App.4th at p. 1779 .) e. Equitable Estoppel Wattar maintains that PSD should be estopped from asserting her failure to satisfy the GCA claim requirements because she did not realize until October 2010 that PSD had actually terminated her employment. 2013(See Munoz v. State of California, supra, 33 Cal.App.4th at p. 1779 .) e. Equitable Estoppel Wattar maintains that PSD should be estopped from asserting her failure to satisfy the GCA claim requirements because she did not realize until October 2010 that PSD had actually terminated her employment. | 1 | 2013–2013 |
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.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.