N.E. v. City of Petaluma CA1/4

California Court of Appeal·Decided July 27, 2026·No. A172167·Unpublished

Opinion

Filed 7/27/26 N.E. v. City of Petaluma CA1/4

NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FIRST APPELLATE DISTRICT

DIVISION FOUR

N.E., a Minor, etc., Plaintiff and Appellant, A172167 v. (Sonoma County CITY OF PETALUMA et al., Super. Ct. No. SCV273886) Defendants and Respondents.

Plaintiff N.E., a minor, by and through her guardian ad litem Rebecca Pederson, filed this wrongful death suit against the City of Petaluma (City) and the Sonoma-Marin Area Rail Transit (SMART), after her father was killed in a motorcycle accident near a SMART train crossing in Petaluma, California. In her operative second amended complaint, N.E. alleges the same claim against both defendants for maintaining a dangerous condition of public property. She alleges the road conditions made it difficult for drivers to detect the median because it had an unmarked and unlit 8-inch median, as well as elevation variances and a curvature in the road. Sustaining demurrers filed by the City and by SMART, the court found that N.E.’s allegations were too general. The court found that she failed to specify the precise defects in the road, the manner in which the alleged defects created a safety hazard, and whether these conditions posed

1 a substantial risk to drivers exercising due care. It also noted that N.E. failed to plead facts sufficient to establish a “hidden trap” or “peculiar condition” that would render defendants liable for a failure to add warning markings or light the roadway, per Government Code sections 830.4 and 830.8. Because N.E. had tried and failed to amend her complaint on two previous occasions, the court sustained the demurrers with prejudice. On appeal, N.E. argues that the trial court erred. She contends she has pled enough specifics to support a viable claim based on the road median and curvature to establish a dangerous condition of public property, as well as a “hidden trap” and “peculiar condition” that would impose a duty on the defendants to provide markings and lighting under Government Code sections 830.4 and 830.8. She argues in the alternative that she should be given another opportunity to amend her complaint, and claims there are more specifics she can add. Respondents, for their part, restate the court’s reasoning and urge unconditional affirmance. We agree that the demurrers were properly sustained, but will remand so that N.E. may seek to cure the defects in her complaint. Given the heightened pleading standard for claims alleged under the Government Claims Act (Gov. Code, § 810 et seq.) (previously known as the Tort Claims Act), N.E. failed to plead enough specifics for viable claims of a dangerous condition of public property (Gov. Code, § 835) or a “hidden trap” and “peculiar condition” that would defeat defendants’ immunity. But we disagree that the demurrer was properly sustained without leave to amend. There is no categorical rule restricting the number of times a plaintiff may amend a complaint. Since N.E. plausibly argues she can add further details that may save her complaint, she should be given another chance to replead.

2 Accordingly, while we will affirm the order sustaining the demurrers, we will remand with directions that the trial court grant N.E. a third opportunity to amend her complaint. I. BACKGROUND In June 2022, N.E.’s father was riding a motorcycle in Petaluma, California when he struck a concrete roadway median in the vicinity of a train crossing controlled by SMART. He sustained fatal injuries. Following the crash, N.E. brought a wrongful death suit against two public entities, the City and SMART, alleging maintenance of a dangerous condition of public property. Each defendant demurred three times, arguing that the complaint as originally filled and as amended twice was legally insufficient. Sustaining these demurrers, the trial court concluded that N.E. failed to explain the specific defects in the roadway complained of and how such defects were hazardous. But twice it granted N.E. an opportunity to amend her complaint. After granting leave to amend a second time, the court noted that “since a demurrer ha[d] already been sustained to this cause of action in the past and [the] Plaintiff ha[d] never explained to the Court how the defects could be cured by amendment, this is the final time [it would] grant leave to amend.” A. Allegations of the Second Amended Complaint In her second amended complaint, N.E. largely restated allegations from her prior complaints. She pleaded a dangerous condition of public property, alleging the roadway had a “dangerous” curvature, a “dangerous” and “unmarked” median and concrete barrier, and “inadequate” warnings, lighting, markings, and signage. As in her first amended complaint, she restated that the “physical characteristics” of the roadway “created vision

3 limitations, obscure elevation variances, and otherwise constituted hidden traps . . . .” But some allegations were new. She alleged that the “8-inch” median was “dangerous and physically defective in design, placement, and due to its physically deteriorated condition.” For support, she stated the median was struck by other vehicles, “as evidenced by numerous wheel strike marks and damage.” She then stated the median was dangerous, because there was an “absence of lighting in the area” and a lack of reflective markings and signage to warn motorists of the median. She alleged that the median was built and designed with warnings, but the warnings were broken and/or removed prior to the accident. B. Trial Court’s Rulings In the order sustaining the third round of demurrers—the order now under review—the trial court began by explaining that “ ‘[t]he limited and statutory nature of government liability mandates that claims against public entities be specifically pleaded.’ (Brenner v. City of El Cajon (2003) 113 Cal.App.4th 434, 439 [(Brenner)].)” (See Gov. Code, §§ 815, 835.) Applying this heightened pleading standard, the court found many of N.E.’s allegations to be too “general,” “unsupported by facts,” and “conclusory.” For instance, the court held that N.E.’s allegations of a “dangerous curvature,” a “dangerous median,” “vision limitations, obscure elevation variances, and . . . hidden traps” were all too “generally pleaded” and that N.E. failed to explain the manner in which those alleged defects created an undue safety hazard. Specifically, with respect to the center median, the court explained that the alleged wheel strike marks on the median and the missing reflective markings were not sufficient to support a viable claim for a dangerous condition of public property or that they established a “hidden

4 trap” or “peculiar condition” that would obligate both defendants to provide warning marks or lighting. Wheel strike marks alone, without any indication the median was “physically deteriorated” or improperly located or designed, do not establish that the median was in a dangerous condition, the court stated. As for the alleged lack of lighting and warning markers, the court noted that public entities have no duty to light their streets and are immune from claims alleging failure to provide warning signals and markings under Government Code sections 830.4 and 830.8. None of N.E.’s factual allegations, the court concluded, amounted to a “peculiar condition” or “hidden trap” that would defeat this immunity. Summing up, the court announced it would once again sustain the defendants’ demurrers, but this time without leave to amend. It noted that since N.E.

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