Bates v. City of Temecula CA4/1

California Court of Appeal·Decided July 20, 2026·No. D086590·Unpublished

Opinion

Filed 7/20/26 Bates v. City of Temecula CA4/1 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

COURT OF APPEAL, FOURTH APPELLATE DISTRICT

DIVISION ONE

STATE OF CALIFORNIA

JOHN GORDON BATES, III, D086590

Plaintiff and Respondent, (Super. Ct. No. CVSW2207919)

v.

CITY OF TEMECULA,

Defendant and Appellant.

APPEAL from an order of the Superior Court of Riverside County, Raquel A. Marquez, Judge. Reversed. Richards, Watson & Gershon, T. Peter Pierce, Ezra Siegel, and Carlee I. Roberts for Defendant and Appellant. Williams Iagmin and Jon R. Williams for Plaintiff and Respondent.

I INTRODUCTION The City of Temecula (the City) appeals an order granting a new trial after a jury found the City not liable for a dangerous condition on a public roadway that allegedly caused John Gordon Bates, III, to crash while riding his bicycle. The trial court granted a new trial because it inadvertently failed to instruct the jury with CACI No. 1103, which provides that a plaintiff in a dangerous condition case may prove the defendant had notice of the dangerous condition by demonstrating that the defendant had actual knowledge of the dangerous condition or, alternatively, by showing that the defendant reasonably should have known about the dangerous condition. The City asks us to reverse the new trial order and reinstate the jury verdict. The City argues the trial court applied an incorrect legal standard when it granted a new trial and, furthermore, Bates suffered no prejudice from the instructional omission. In defense of the new trial order, Bates claims the court applied the correct legal standard and acted within its discretion when it impliedly found the instructional omission prejudiced him. He also contends the court committed an unrelated error warranting a new trial because it unintentionally provided the jury with a grayscale version of an exhibit that should have been printed partially in color. We agree with the City that the instructional omission did not prejudice Bates. We also reject Bates’s claim that the jury’s receipt of a grayscale version of the exhibit constituted a prejudicial miscarriage of justice entitling him to a new trial. Therefore, we reverse the order granting a new trial, and remand the matter to the trial court with instructions to enter judgment for the City consistent with the jury verdict. II BACKGROUND A. The Bicycling Accident On the afternoon of March 7, 2022, Bates was riding his bicycle from his workplace at Camp Pendleton to his home in Temecula, 37 miles away. Towards the end of his ride, he traveled on a two-lane 1.5-mile road in Temecula called Rainbow Canyon Road. Bates reached the peak of a hill and

2 then began descending with the flow of traffic at a speed of about 25 miles per hour. As he descended, Bates allegedly felt the front of his bicycle suddenly dip into a crack or pothole in the road, causing him to pitch forward over his handlebars and land on the road. Bates was pulled to the roadside by bystanders and transported to a hospital where he was treated for injuries he sustained during the accident. Due to the rapid speed at which Bates was travelling, the unexpected nature of the accident, and the existence of multiple cracks and potholes in the road, Bates was uncertain of the exact cause of his accident. He initially believed the cause was a crack in the road near where he came to rest after the accident. However, he later retained an accident reconstruction expert, who opined that the likely cause of the accident was a pothole located further uphill from Bates’s final resting place. After Bates reviewed his accident reconstruction expert’s analysis, he also came to believe his accident was caused by the pothole located uphill from his resting place. At trial, Bates simply maintained that his tire “went into something …. It went into a crack, one of the cracks in the road, one of the holes in the road.” B. The Dangerous Condition Trial On November 23, 2022, Bates filed a single-count complaint against the City alleging a dangerous condition on public property in violation of Government Code section 835. The case proceeded to a jury trial. One of the central issues at trial was whether the City had notice of the crack or pothole in the road that allegedly caused Bates’s accident. One witness who testified about this issue was Rodney Tidwell, the Maintenance Manager for the City’s Public Works Department. Tidwell testified that the City retains a third-party vendor to drive the City’s roads and provide the City with ratings for the roads. The vendor prepares a Pavement Condition

3 Index (PCI) with scores for each road ranging from 0 to 100. Roads with scores ranging from 25 to 40 are poor roadways that may need thick overlays or extensive maintenance and repairs. Roads with scores ranging from 0 to 25 are very poor roadways for which full reconstruction is recommended. According to Tidwell, a PCI score is given for an entire road and not a specific subsection of the road. The PCI score for Rainbow Canyon Road ranged from 10 to 30, and Tidwell testified he has been “generally aware” of the road’s PCI scores since 2014. However, prior to Bates’s accident, Tidwell had never received a work order request for a roadway condition near the area in which Bates’s accident occurred. He was also unaware of any other bicycling accidents in the area prior to Bates’s accident. Another related issue that arose during trial was the duration of time the crack or pothole at issue had existed before the accident, which was relevant to whether the City had constructive notice of the dangerous condition. Bates testified he drove on Rainbow Canyon Road three times per week and rode his bike on the road about 40 times in the 10-month period preceding his accident. In total, he claimed he had been on the road more than 100 times during that timeframe. Even so, Bates testified he never saw or noticed the crack or pothole. He also did not know how or when the crack or pothole originated. During the jury instruction conference, the parties stipulated to several pattern instructions pertinent to Bates’s dangerous condition claim, including CACI No. 1100 (“Dangerous Condition on Public Property—Essential Factual Elements”), CACI No. 1102 (“Definition of ‘Dangerous Condition’ ”), CACI No. 1103 (“Notice”), and CACI No. 1104 (“Inspection System”). When the court later instructed the jury, however, it inadvertently omitted CACI

4 No. 1103.1 CACI No. 1103 states that the plaintiff can satisfy the element of notice by establishing that the defendant had either actual knowledge of the dangerous condition or, alternatively, constructive knowledge of the

dangerous condition.2 No party objected or notified the court about its unintentional failure to instruct the jury with CACI No. 1103. Although the court did not instruct the jury with CACI No. 1103, Bates’s trial counsel discussed the difference between actual notice and constructive notice during closing arguments, informed the jury that Bates could satisfy the element of notice if he established either type of notice, and claimed the City was liable because it had both actual notice and constructive notice. Thereafter, during the City’s closing arguments, defense counsel read CACI No. 1103 aloud to the jury and displayed the text of the instruction to the jury in a PowerPoint presentation. Like Bates’s trial counsel, the City’s trial counsel reiterated the difference between actual notice and constructive

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