N.M. Stat. § 41-4-16 (2026)

A. Every person who claims damages from the state or any local public body under
the Tort Claims Act shall cause to be presented to the risk management division for
claims against the state, the mayor of the municipality for claims against the
municipality, the superintendent of the school district for claims against the school
district, the county clerk of a county for claims against the county, or to the
administrative head of any other local public body for claims against such local public
body, within ninety days after an occurrence giving rise to a claim for which immunity
has been waived under the Tort Claims Act, a written notice stating the time, place and
circumstances of the loss or injury.

    B. No suit or action for which immunity has been waived under the Tort Claims Act
shall be maintained and no court shall have jurisdiction to consider any suit or action
against the state or any local public body unless notice has been given as required by
this section, or unless the governmental entity had actual notice of the occurrence. The
time for giving notice does not include the time, not exceeding ninety days, during which
the injured person is incapacitated from giving the notice by reason of injury.

    C. When a claim for which immunity has been waived under the Tort Claims Act is
one for wrongful death, the required notice may be presented by, or on behalf of, the
personal representative of the deceased person or any person claiming benefits of the
proceeds of a wrongful death action, or the consular officer of a foreign country of which
the deceased was a citizen, within six months after the date of the occurrence of the
injury which resulted in the death; but if the person for whose death the claim is made
has presented a notice that would have been sufficient had he lived, an action for
wrongful death may be brought without any additional notice.

History: 1953 Comp., § 5-14-14.1, enacted by Laws 1977, ch. 386, § 12.

                                      ANNOTATIONS
Emergency clauses. — Laws 1977, ch. 386, § 23 contained an emergency clause and
was approved April 8, 1977.

Constitutional right to access courts not violated. — The 90-day notice provision of
the Tort Claims Act [41-4-1 through 41-4-27 NMSA 1978] does not violate the
constitutional right of access to the courts. The legislative purposes requiring timely and
reasonable notice to a governmental entity of potential claims are rationally related to
legitimate governmental interests such as: (1) to allow investigation of a matter while the
evidence is fresh; (2) to allow questioning of witnesses; (3) to protect against stimulated
or aggravated claims; or (4) to allow consideration of whether a claim should be paid or
not. Powell v. N.M. State Hwy. & Transp. Dep't, 1994-NMCA-035, 117 N.M. 415, 872
P.2d 388, cert. denied, 117 N.M. 524, 873 P.2d 270.

Due process. — The notice requirement is not unreasonably short, thus not
constituting a denial of due process. Ferguson v. N.M. State Hwy. Comm'n, 1982-
NMCA-180, 99 N.M. 194, 656 P.2d 244, cert. denied, 99 N.M. 226, 656 P.2d 889
(1983).

The period of giving notice does not deny an incapacitated victim due process of law.
Ferguson v. N.M. State Hwy. Comm'n, 1982-NMCA-180, 99 N.M. 194, 656 P.2d 244,
cert. denied, 99 N.M. 226, 656 P.2d 889 (1983).

Application of the notice provision of Subsection A to any minor, whatever the
circumstances, would not, in every circumstance, violate due process. Erwin v. City of
Santa Fe, 1993-NMCA-065, 115 N.M. 596, 855 P.2d 1060.

Section inapplicable to claims against public employees. — The language of the
written notice section does not include, and therefore does not apply to, claims against
public employees. Martinez v. City of Clovis, 1980-NMCA-078, 95 N.M. 654, 625 P.2d
583, cert. denied, 94 N.M. 674, 615 P.2d 991.

The written notice requirement of Subsection A does not apply to public employees,
such as a mayor or a police chief. Frappier v. Mergler, 1988-NMCA-021, 107 N.M. 61,
752 P.2d 253.

Section inapplicable to claims only against public employee. — Where a police
officer was sued individually in federal court for violation of plaintiff’s constitutional
rights, the officer asked the municipality to provide a defense and gave a copy of the
complaint to the municipal attorney; the municipality refused to provide a defense; the
municipality had actual notice of the federal action and was asked to provide a defense
within the time for filing an answer to the complaint; the municipality did not dispute that
the officer acted within the scope of the officer’s employment; the officer defended the
federal action pro se; and the officer and plaintiff settled the federal claims; and plaintiff
did not give the municipality written notice of the incident within ninety days after the
incident occurred, 41-4-16 NMSA 1978 does not require notice to be given by a
claimant who sues only a governmental employee and the municipality was required to
defend and indemnify the officer and pay the judgment against the officer. Niederstadt
v. Town of Carrizozo, 2008-NMCA-053, 143 N.M. 786, 182 P.3d 769, cert. denied,
2008-NMCERT-003, 143 N.M. 681, 180 P.3d 1180.

Purpose of the notice requirement is four-fold: (1) to enable the person or entity to
whom notice must be given, or its insurance company, to investigate the matter while
the facts are accessible; (2) to question witnesses; (3) to protect against simulated or
aggravated claims; and (4) to consider whether to pay the claim or to refuse it.
Ferguson v. N.M. State Hwy. Comm'n, 1982-NMCA-180, 99 N.M. 194, 656 P.2d 244,
cert. denied, 99 N.M. 226, 656 P.2d 889 (1983).

Affidavit stating intent to make claims attached to a pleading was sufficient
notice. — Where plaintiff, as personal representative of her deceased son's estate,
brought a class action complaint for medical and other negligence against the university
of New Mexico hospital (UNMH) resulting from treatment provided to pediatric cancer
patients at UNMH, the district court erred in dismissing plaintiff's claims on grounds that
UNMH did not receive notice of plaintiff's claims as required by the Tort Claims Act,
because plaintiff, as representative of her deceased son, fell within the class described
in two pending class action lawsuits against UNMH, and UNMH had accepted service of
the class action lawsuits, and plaintiff had filed an affidavit in support of a motion to
consolidate the two class actions that gave UNMH notice that plaintiff actually intended
to make claims against UNMH for losses and injuries allegedly caused by the
negligence alleged in the class action complaints. Cummings v. UNM Bd. of Regents,
2019-NMCA-034, cert. denied.

Notice was timely. — Where plaintiff, as personal representative of her deceased son's
estate, brought a class action complaint for medical and other negligence against the
university of New Mexico hospital (UNMH) resulting from treatment provided to pediatric
cancer patients at UNMH, and where plaintiff provided notice of a claim by executing an
affidavit stating that plaintiff intended to make claims against UNMH for losses and
injuries allegedly caused by the negligence of UNMH, and where the affidavit was filed
in a court pleading within six months of plaintiff discovering the facts relevant to her
claim against UNMH, the notice to UNMH was timely. Cummings v. UNM Bd. of
Regents, 2019-NMCA-034, cert. denied.

Plaintiff’s report failed to satisfy the purpose of the notice requirement. — Where
the purpose of the Tort Claims Act [41-4-1 through 41-4-27 NMSA 1978] notice
requirement is to ensure that the agency allegedly at fault is notified that it may be
subject to a lawsuit and to reasonably alert the agency to the necessity of investigating
the merits of a potential claim against it, and where plaintiff, a resident physician at the
university of New Mexico school of medicine, filed a report with residency administrators
alleging that she was raped by a senior resident in the residency program, the report
was insufficient to notify defendant of a likelihood that litigation may ensue; the district
court did not err in dismissing plaintiff’s tort claim for failure to comply with the Tort
Claim Act’s notice requirement. Herald v. Board of Regents of the Univ. of N.M., 2015-
NMCA-104, cert. denied, 2015-NMCERT-009.
Contents of notice. — Subsection B does not require that the notice of a claim under
this article indicate that a lawsuit will in fact be filed against the state, but, rather, it
contemplates that the state must be given notice of a likelihood that litigation may
ensue, in order to reasonably alert it to the necessity of investigating the merits of a
potential claim against it. Smith v. State ex rel. N.M. Dep't of Parks & Recreation, 1987-
NMCA-111, 106 N.M. 368, 743 P.2d 124.

The notice required is not simply actual notice of the occurrence of an accident or injury
but rather actual notice that there exists a likelihood that litigation may ensue. Dutton v.
McKinley Cnty. Bd. of Comm'rs, 1991-NMCA-130, 113 N.M. 51, 822 P.2d 1134.

Although the plaintiff claimed that the department had actual notice of this claim
because of: (1) the information contained in a police report, (2) information derived from
the conversation between a maintenance foreman and the police officer investigating
the accident, and (3) the department's special knowledge concerning the hazards of
blunt-edged guardrails, there was no evidence that the department had notice that this
particular accident was likely to result in litigation against the department, or that the
plaintiff considered the accident to be the department's fault. The above factors did not
satisfy the requirement of actual notice. Powell v. N.M. State Hwy. & Transp. Dep't,
1994-NMCA-035, 117 N.M. 415, 872 P.2d 388, cert. denied, 117 N.M. 524, 873 P.2d
270.

Plaintiffs' notice of claims was sufficient to satisfy Subsection A of this section.
— Where in 2016, plaintiffs, the family and personal representative of the decedent,
sent notice of claims resulting in injury and death to the Bernalillo county clerk, the New
Mexico risk management division, and the mayor of the city of Albuquerque (city), and
where, in 2017, plaintiffs filed a complaint under the Tort Claims Act (TCA) alleging
negligence by the city of Albuquerque, Albuquerque police department (APD), and
unknown officers, including negligence in failing to investigate a referral made by the
children, youth and families department that arose from an incident before the decedent
was killed, and where the district court granted the city's motion for summary judgment
for failing to comply with the TCA requirement to give written notice of plaintiffs' claims,
concluding that the notice's allegation of "failure to properly monitor a person on
probation" did not reasonably alert the city to the necessity of investigating the merits of
a claim that it failed to investigate a report of child abuse, the district court erred in
granting the motion for summary judgment, because the time, place, and circumstance
in the notice satisfied 41-4-16(A) 1978 NMSA and did not differ from the time, place,
and circumstance of the loss in the subsequent complaint. Martens v. City of
Albuquerque, 2025-NMSC-018, aff'g 2023-NMCA-037

Contents of notice satisfied the written notice requirement. — Where plaintiffs,
individually, and on behalf of the estate of decedent, sent a "Notice of Claims Resulting
in Injury/Death" to the Bernalillo county clerk, the risk management division, and the
mayor of the city of Albuquerque, stating that decedent, a minor child, suffered serious
injuries and subsequent death after certain government employees failed to properly
monitor decedent’s alleged killer, who was on probation at the time of the murder, and
where plaintiffs subsequently filed a complaint, alleging that the city of Albuquerque, the
Albuquerque police department, and unknown officers were negligent in failing to
investigate a referral made by the children, youth and families department that arose
from an incident before decedent was killed, and where the district court dismissed the
complaint, finding that the "Notice of Claims" failed to advise the city that the claim
related to the duty to investigate a child abuse referral, because the notice referenced a
failure to supervise a probationer and thus "misdirected and thwarted any inquiry into
whether the claim should be denied or should be paid," the district court erred in
dismissing the complaint, because the Notice of Claims stated the time, place, and
circumstances of the injury by generally referring to the tortious conduct and negligence
by the state, the county, and the city, which caused decedent’s injuries and death on
August 24, 2016. The city was made aware that a claim could be brought based on the
crime committed against decedent and associated negligence and tortious conduct
leading to that crime, and therefore the notice provided the city with the information
necessary to investigate its involvement with the circumstances leading to decedent’s
injuries and death. Martens v. City of Albuquerque, 2023-NMCA-037, cert. granted.

Notice of time, place and circumstances of fatal collision was sufficient under the
Tort Claims Act. — Where plaintiffs sued defendant New Mexico department of
transportation under the New Mexico Tort Claims Act (NMTCA) on the theory of
negligent road maintenance, and where defendant argued that plaintiffs did not comply
with the NMTCA notice requirements and thus the district court lacked subject matter
jurisdiction, defendant's claim was without merit, because notice is sufficient where
there is a correlation between the allegations in a written notice and allegations in a
lawsuit's complaint, and in this case, plaintiffs mentioned that claims would be brought
against defendant and gave at least some indication of what those claims might be
when they included the time, place, and circumstances of the fatal collision. That
plaintiffs did not identify in their notice letter the specific theory later pursued in their
complaint is not fatal to the propriety of plaintiffs' notice. Hoeschen v. N.M. Dep't of
Transp., 2026-NMCA-023, cert. denied.

To whom notice necessary. — In an action against the state park and recreation
department, for its alleged negligence resulting in a boating accident and ensuing
deaths, notice given to both the superintendent of the state park where the drownings
occurred and to the boating supervisor at the park, satisfied the notice requirements
specified in this section. Notice did not have to be given to the head of the department
or its risk management division. Smith v. State ex rel. N.M. Dep't of Parks & Recreation,
1987-NMCA-111, 106 N.M. 368, 743 P.2d 124.

The "actual notice" required by Subsection B is not simply actual notice of the
occurrence of an accident or injury but rather, actual notice that there exists a
"likelihood" that litigation may ensue. Frappier v. Mergler, 1988-NMCA-021, 107 N.M.
61, 752 P.2d 253.

Lack of notice relieving state from liability. — State was not responsible, under the
Tort Claims Act, for paying a federal court judgment against a penitentiary guard when
neither the state nor any of its agencies had notice of either the claim or of the federal
court suit. Otero v. State, 1987-NMCA-054, 105 N.M. 731, 737 P.2d 90, cert. denied,
105 N.M. 707, 736 P.2d 985.

Notice begins to run when injury manifests itself. — Where the language of this
section's notice provisions and the statute of limitations, 41-4-15 NMSA 1978, is similar,
the rule that the statute of limitations period begins to run from the time an injury
manifests itself in a physically objective manner and is ascertainable is an applicable
precedent to the question of when, under the Tort Claims Act, notice begins to run.
Emery v. Univ. of N.M. Med. Ctr., 1981-NMCA-059,96 N.M. 144, 628 P.2d 1140.

Notice defense may not be stricken as insufficient. — The notice defense accorded
by this section is a defense under which a defendant may be entitled to relief against a
plaintiff's claim and, thus, is not to be stricken as insufficient as a matter of law. Emery
v. Univ. of N.M. Med. Ctr., 1981-NMCA-059, 96 N.M. 144, 628 P.2d 1140.

Notice requirements of Subsections A and B may not be applied to bar infant's
claim. — One unable to comply with a notice requirement by reason of minority is
protected by the reasonableness requirements of the common law and the U.S. Const.,
amend. XIV, or similar provisions in the state constitution. Tafoya v. Doe, 1983-NMCA-
070, 100 N.M. 328, 670 P.2d 582, cert. quashed sub nom., 100 N.M. 327, 670 P.2d
581.

The 90-day notice provision does not apply to minors who are incapable themselves of
meeting that responsibility, and minors may not be held to such notice when their
parents or other relatives are shown to be unable to provide notice for them. Rider v.
Albuquerque Pub. Sch., 1996-NMCA-090, 122 N.M. 237, 923 P.2d 604.

Two-year statute of limitations applicable to negligence suit involving public
utility's employee. — Section 41-4-15 NMSA 1978 of the Tort Claims Act, allowing two
years to bring suit, and not the one-year limitation of 37-1-24 NMSA 1978, which refers
to the time for bringing suits in negligence against any city, town or village, or any
officers thereof, applies to a suit for negligence of a public employee in the operation of
a public utility. Cozart v. Town of Bernalillo, 1983-NMCA-053, 99 N.M. 737, 663 P.2d
713.

Notice to adjustor sufficient. — Notice to an adjustor acting for his principal, and
known to the claimant to be the adjustor for the principal, is sufficient notice to satisfy
the statute requiring notice to the principal. Martinez v. City of Clovis, 1980-NMCA-078,
95 N.M. 654, 625 P.2d 583, cert. denied, 94 N.M. 674, 615 P.2d 991.

Police report not "actual notice". — An accident report prepared by the state police
does not constitute actual notice to the state and to all state agencies. Mere notice of an
accident will not necessarily put the government entity on notice that it may become the
defendant in a lawsuit. Marrujo v. N.M. State Hwy. Transp. Dep't, 1994-NMSC-116, 118
N.M. 753, 887 P.2d 747.
"Incapacitated," for purposes of giving notice. — A person is incapacitated for
purposes of giving notice under the Tort Claims Act if the person was, on the days
incapacity is claimed, unable as a result of their injury to prepare and give notice of their
tort claim, or was unable to cause another to give such notice on their behalf. Conklin v.
Sierra Vista Hosp. Governing Bd., 2026-NMCA-008, cert. granted.

Where jurisdictional question was intertwined with the merits, the district court
erred in granting summary judgment motion when there was a genuine dispute of
fact. — Where plaintiff filed a complaint for damages resulting from negligence, medical
negligence, and hospital negligence against the hospital that treated her for severe
burns, and where defendant moved to dismiss plaintiff's claims, arguing that the district
court lacked subject matter jurisdiction due to plaintiff's failure to provide timely notice of
her claim as required by the Tort Claims Act, the district court erred in granting
defendant's motion for summary judgment and in finding that plaintiff was not
"incapacitated from giving the notice by reason of injury," because the question of
plaintiff's incapacity was a jurisdictional question intertwined with the merits, and
therefore any genuine dispute of fact must be resolved by a jury as a threshold matter to
determine jurisdiction. Conklin v. Sierra Vista Hosp. Governing Bd., 2026-NMCA-008,
cert. granted.

Incident report at detention center did not give actual notice that litigation was
likely to ensue. — Where plaintiff, while incarcerated in the Curry county detention
center (CCDC), was assaulted by another inmate, and where the assault was
documented in two separate incident reports at the CCDC, and where plaintiff asserted
claims against CCDC for violations of the fourteenth amendment and negligence under
the New Mexico Tort Claims Act, the court was without jurisdiction to hear the case
because CCDC did not have actual notice that litigation was likely to ensue, because
the incident report, although documenting that an assault took place, did not indicate
that any action by the guards or any other detention center personnel led to the incident
or contributed in any way to plaintiff's injuries and contained no information that
reasonably would have led the county officials to believe litigation against the jail may
ensue as a result; actual notice of the incident or injury alone is insufficient. Galvan v.
Bd. of Cty. Comm'rs for Curry Cty., 261 F.Supp.3d 1140 (D. N.M. 2017).

Plaintiff was not incapacitated from giving notice by reason of injury. — Where
plaintiff, while incarcerated in the Curry county detention center (CCDC), was assaulted
by another inmate, and where plaintiff asserted claims against CCDC for violations of
the fourteenth amendment and negligence under the New Mexico Tort Claims Act, and
where plaintiff failed to comply with this section's 90-day written notice requirement, and
the CCDC did not have actual notice that litigation was likely to ensue, plaintiff was not
incapacitated from giving the tort claims notice by reason of injury because evidence
showed that plaintiff's capacity and capabilities were not meaningfully disrupted by the
assault she received or the injuries stemming from it. Galvan v. Bd. of Cty. Comm'rs for
Curry Cty., 261 F.Supp.3d 1140 (D. N.M. 2017).
Actual notice requires notice that there exists a likelihood that litigation may
ensue. — Where plaintiff filed a lawsuit asserting claims against the Bernalillo county
metropolitan detention center (BCMDC) for violations of the New Mexico Tort Claims
Act after a state district court remanded plaintiff to BCMDC to participate in a
methadone program to decrease his level of dependence so that he would not incur life
endangering withdrawal symptoms, but where plaintiff suffered life threatening
withdrawal symptoms for approximately two months after being transferred to the New
Mexico corrections department in contravention of the state district court’s order, the
federal district court was without jurisdiction over the tort claims, because plaintiff did
not provide written notice to Bernalillo county and there was not sufficient evidence
showing that Bernalillo county had actual notice that there existed a likelihood that
litigation may ensue in order to reasonably alert the county to the necessity of
investigating the merits of the potential claim. Gallegos v. Bernalillo County Board of
County Commissioners, 278 F.Supp.3d 1245 (D.N.M. 2017).

Report serves as notice if governmental entity made aware of claim. — Under
some circumstances, a police or other report could serve as actual notice under
Subsection B, but only where the report contains information which puts the
governmental entity allegedly at fault on notice that there is a claim against it. Guerra,
City of Las Cruces v. Garcia, 1984-NMSC-106, 102 N.M. 25, 690 P.2d 1019.

Report may serve as notice if agency has knowledge of potential liability. — When
the governmental entity allegedly at fault has knowledge of the facts and circumstances
of an occurrence, it may have knowledge of its own potential liability, and a particular
statement by a victim that there may be a claim is not required. Lopez v. State, 1996-
NMSC-071, 122 N.M. 611, 930 P.2d 146.

Notice provisions operate as statutes of limitations since they are conditions
precedent to filing a suit. Ferguson v. N.M. State Hwy. Comm'n, 1982-NMCA-180, 99
N.M. 194, 656 P.2d 244, cert. denied, 99 N.M. 226, 656 P.2d 889 (1983).

If governmental entity creates condition that causes injury, notice is still required
of a claim for damages. This section operates in conjunction with 41-4-15 NMSA 1978,
the statute of limitations section, on the issue of a timely claim. Tafoya v. Doe, 1983-
NMCA-070, 100 N.M. 328, 670 P.2d 582, cert. quashed sub nom., 100 N.M. 327, 670
P.2d 581.

Actual notice of accident. — An evidentiary hearing may be required to decide the
threshold issue whether, from actual notice of an occurrence, a governmental entity was
on notice that it could be subject to a claim. Lopez v. State, 1996-NMSC-071, 122 N.M.
611, 930 P.2d 146.

Burden of proof that notice requirements not met. — It is the defendants' burden to
sustain their defense that the notice requirements had not been met. Ferguson v. N.M.
State Hwy. Comm'n, 1981-NMCA-071, 98 N.M. 718, 652 P.2d 740, rev'd on other
grounds, 1982-NMSC-107, 98 N.M. 680, 652 P.2d 230.
Police accident report not "actual notice". — An accident report prepared by the
New Mexico state police does not constitute "actual notice," within the meaning of
Subsection B, to the state and to all state agencies. N.M. State Hwy. Comm'n v.
Ferguson, 1982-NMSC-107, 98 N.M. 680, 652 P.2d 230.

Weight given statements made in workmen's compensation suits. — Since cases
arising under the Tort Claims Act [41-4-1 through 41-4-27 NMSA 1978] almost always
present issues of first impression, statements made in workmen's compensation (now
workers' compensation) suits regarding the reason for notice should be accorded great
weight. Martinez v. City of Clovis, 1980-NMCA-078, 95 N.M. 654, 625 P.2d 583, cert.
denied, 94 N.M. 674, 615 P.2d 991.

Federal preemption. — The Tort Claims Act [41-4-1 through 41-4-27 NMSA 1978]
notice-of-claim requirement is preempted by the federal Emergency Medical Treatment
and Active Labor Act, 42 U.S.C. § 1395dd, and, therefore, is not applicable to an
Emergency Act claim. Godwin v. Mem'l Med. Ctr., 2001-NMCA-033, 130 N.M. 434, 25
P.3d 273, cert. quashed, 132 N.M. 193, 46 P.3d 100, and cert. denied, 537 U.S. 885,
123 S. Ct. 118, 154 L. Ed. 2d 144 (2002).

Summary judgment inappropriate. — Where undisputed facts of the case allow the
trier of fact to draw equally logical but conflicting inferences from the facts, summary
judgment on the issue of whether the department of corrections had actual notice of the
occurrence as required by subsection B is not appropriate. Calloway v. N.M. Dep't of
Corr., 1994-NMCA-049, 117 N.M. 637, 875 P.2d 393, cert. denied, 118 N.M. 90, 879
P.2d 91.

Law reviews. — For article, "Constitutional Torts and the New Mexico Torts Claims
Act," see 13 N.M.L. Rev. 1 (1983).

Am. Jur. 2d, A.L.R. and C.J.S. references. — 56 Am. Jur. 2d Municipal Corporations,
Counties, and Other Political Subdivisions §§ 680, 719, 737, 760, 773, 776, 782.

Attorney's mistake or neglect as excuse for failing to file timely notice of tort claim
against state or local governmental unit, 55 A.L.R.3d 930.

Actual notice or knowledge by governmental body or officer of injury or incident resulting
in injury as constituting required claim or notice of claim for injury - modern status, 7
A.L.R.4th 1063.

Local government tort liability: minority status as affecting notice of claim requirement,
58 A.L.R.4th 402.

Insufficiency of notice of claim against municipality as regards statement of place where
accident occurred, 69 A.L.R.4th 484.
Complaint as satisfying requirement of notice of claim upon states, municipalities, and
other political subdivisions, 45 A.L.R.5th 109.

Persons or entities upon whom notice of injury or claim against state or state agencies
may or must be served, 45 A.L.R.5th 173.

Sufficiency of notice of claim against local governmental unit as regards identity, name,
address, and residence of claimant, 53 A.L.R.5th 617.

Sufficiency of notice of claim against local political entity as regards time when accident
occurred, 57 A.L.R.5th 689.

Waiver of, or estoppel to assert, failure to give or defects in notice of claim against state
or local political subdivision - modern status, 64 A.L.R.5th 519.

63 C.J.S. Municipal Corporations §§ 922 to 930; 81A C.J.S. States § 310.