Meddock

A Fremont cottonwood tree fell on plaintiff Dwight Meddock while he was in a paved parking lot located in a park along the Sacramento River owned by defendant County of Yolo (County). The trial court granted summary judgment against Meddock and his wife (collectively, Meddock) in their tort suit alleging a dangerous condition of public property, by applying statutory immunity for injuries “caused by a natural condition of any unimproved public property.” (Gov. Code, § 831.2, hereafter section 831.2.) As we will explain, we conclude that Meddock’s injuries were “caused by” a “natural condition” of unimproved property where the tree grew, and the fact the tree fell on the improved portion of the public property does not take this case outside the ambit of the immunity.

Accordingly, we shall affirm the judgment in favor of the County.

FACTUAL AND PROCEDURAL BACKGROUND

The Pleadings

This case involves the Government Claims Act (Gov. Code, § 810 et seq.; see City of Stockton v. Superior Court (2007) 42 Cal.4th 730, 741-742 [ 68 Cal.Rptr.3d 295 , 171 P.3d 20 ].)

The operative complaint alleged that on March 21, 2009, Meddock was injured when a tree fell on him while he…