June 11, 2026
Court of Appeal of the State of California, First Appellate District, Division Three
The Rule of County of Del Norte v. Britt is that a responding party who prevails in a receivership proceeding under Health and Safety Code section 17980.7(c) is entitled to attorney fees and court costs under section 17980.7(c)(11), even against a municipal enforcement agency, because this more recent and specific statute creates an exception to the general rule of section 17984 that shields public agencies from cost liability, under circumstances where the responding party was improperly named as a defendant and achieved complete vindication on the claims against them.
March 11, 2026
Court of Appeal, Second Appellate District, Division Five
The Rule of Yan v. City of Diamond Bar is that evidence of prior branch failures from the same tree species in the same vicinity is admissible to prove a public entity's actual or constructive notice of a dangerous condition, under circumstances where the trees share common characteristics (same species, maintenance schedule, and environmental factors) and the evidence demonstrates a pattern of recurring problems that should attract the entity's attention to a condition requiring correction.