Meddock v. County of Yolo
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 a statutory immunity for injuries “caused by a natural condition of any unimproved public property[.]†(Gov. Code, § 831.2, hereafter § 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.



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