Third District Court of Appeal Publishes Weather Immunity Decision

Shareholder Matt Gross successfully affirmed a summary judgment ruling for the County of Nevada in the Third District Court of Appeal. In a recent published decision, Rhonna Tindall v. County of Nevada (2025) – Cal.Rptr.3d –, 2025 WL 1702999, the Court determined that the County was entitled to weather immunity under Government Code § 831 for the presence of snow and ice in the County Jail parking lot. The Court found under Government Code § 831 the definition of a “street or highway” also included a parking lot. The Court also determined that a reasonable prudent person would have understood the presence of snow and ice in the parking lot can lead to slippery conditions for pedestrians. This published case represents the first case in over 30 years analyzing Government Code § 831 weather immunity.