California Slip and Fall Demand Letters
Stores, restaurants, and public places under California law

California slip and fall law: When you're injured in a slip, trip, or fall at a California store, restaurant, mall, or other public property, the property owner or business operator may be liable under California premises liability law. California applies a general duty of reasonable care to all property owners, regardless of traditional visitor classifications.

Successful California slip and fall claims require proving the owner knew or should have known about the dangerous condition through reasonable inspections. This guide covers California-specific duty frameworks, constructive notice standards, how to draft California demand letters, and settlement realities in California venues.

I handle California slip and fall demand letters personally. This page focuses on California law, including Civil Code § 1714, Rowland v. Christian, and the Ortega inspection-failure doctrine that governs most retail and restaurant fall cases.

California premises liability duty framework

California premises liability law differs significantly from other states. In 1968, the California Supreme Court abolished the traditional invitee/licensee/trespasser framework and replaced it with a general duty of reasonable care.

Rowland v. Christian: General duty of care

In Rowland v. Christian (1968) 69 Cal.2d 108, the California Supreme Court held that property owners owe a general duty of reasonable care to all persons on their property, regardless of status. Instead of rigid categories, California courts analyze duty based on:

  • Foreseeability of harm: Was injury to this type of visitor reasonably foreseeable?
  • Certainty of injury: How likely was injury from this condition?
  • Closeness of connection: Did the owner's conduct directly relate to the injury?
  • Moral blame: Is the owner's conduct blameworthy?
  • Policy of preventing harm: Will liability encourage safer property maintenance?
  • Burden on defendant: How onerous is the duty to inspect and repair?
  • Availability of insurance: Can the owner reasonably insure against this risk?
Key advantage for California plaintiffs: You don't need to prove you were an "invitee" or that the property was "open to the public." California law imposes a general duty of reasonable care on all property owners toward all lawful visitors.
Civil Code § 1714: Everyone is responsible for their negligence

California Civil Code § 1714(a) states: "Everyone is responsible, not only for the result of his or her willful acts, but also for an injury occasioned to another by his or her want of ordinary care or skill in the management of his or her property or person."

This statute establishes the baseline duty for all California premises liability claims, including slip and fall cases in stores, restaurants, malls, parking lots, and public buildings.

CACI jury instructions for California premises cases

California jury trials use CACI (California Civil Jury Instructions) for premises liability claims:

  • CACI 1000: Basic negligence instruction (duty, breach, causation, damages)
  • CACI 1003: Premises liability instruction for dangerous conditions
  • CACI 1005: Constructive notice based on reasonable inspection

When drafting your demand letter, reference these instructions to show how California juries will evaluate your case if it goes to trial.

Where California slip and falls happen
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Big box stores & groceries
Walmart, Target, Costco, Safeway, Trader Joe's, Whole Foods. Spills in aisles, wet entrance mats, produce sections, parking lots.
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Restaurants & cafes
Fast food, casual dining, fine dining. Grease on floors, spilled drinks, wet entryways, uneven mats, cracked tiles.
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Shopping malls & plazas
Common areas, food courts, escalators, parking structures. Landlord vs tenant liability issues.
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Public buildings
Libraries, transit stations, courthouses. Government Claims Act applies; 6-month claim deadline.
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Sidewalks & walkways
Cracked concrete, tree roots, uneven pavement. Business owner vs city liability; Government Claims Act issues.
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Parking lots & structures
Potholes, speed bumps, poor lighting, oil slicks, uneven surfaces.
Ortega v. Kmart: The constructive notice rule for California stores

The most important California premises liability case for slip and fall claims is Ortega v. Kmart Corp. (2001) 26 Cal.4th 1200. This case defines how California plaintiffs prove constructive notice in retail settings.

What Ortega held

Ortega established that a store can be liable for slip and fall injuries based on circumstantial evidence that it failed to conduct reasonable inspections—even if the plaintiff cannot prove exactly how long the hazard existed.

Key holding: If a store fails to show it had reasonable inspection and cleanup procedures, a California jury may infer the hazard was on the floor long enough that reasonable inspections would have discovered it. This shifts the burden to the store to prove it had adequate procedures.
How to use Ortega in your demand letter

In California slip and fall demand letters, explicitly reference Ortega and argue:

  • Lack of sweep logs: Store cannot produce time-stamped inspection records showing recent sweeps of the area where you fell.
  • Insufficient inspection frequency: Store's policy (e.g., "sweep every 2 hours") is inadequate given high foot traffic and nature of business.
  • No employee presence: Long aisles with infrequent employee patrols; hazard could have existed for extended period undetected.
  • Recurring spill area: Prior complaints or incidents in same location show store knew area was prone to spills.
Example Ortega argument: "Under Ortega v. Kmart, the store is liable if it failed to maintain reasonable inspection procedures. The store cannot produce sweep logs for the hour before my fall, and employees stated they had not inspected Aisle 12 that morning. This evidence permits an inference that the spill existed long enough to be discovered through reasonable inspections."
Actual vs constructive notice in California

Like other states, California requires proof of notice. But Ortega makes constructive notice easier to establish:

Notice Type How to Prove in California
Actual notice Employee created hazard, saw hazard, or was told about it. Surveillance video, witness testimony, incident reports.
Constructive notice Under Ortega, show store failed to implement reasonable inspection procedures. Lack of sweep logs, inadequate inspection frequency, or no employee presence in area.
Requesting inspection evidence in your demand

Your California demand letter should explicitly demand preservation and production of:

  • Sweep logs and inspection records for the day of your fall
  • Employee schedules showing who was assigned to the area
  • Written inspection policies and training materials
  • Prior incident reports for the same area or similar hazards
  • Surveillance video showing when hazard appeared and how long it existed
Spoliation warning: Include language in your demand letter warning that destruction of inspection records, video, or logs may result in adverse inference at trial and potential punitive damages for intentional spoliation.
Building your California slip and fall demand letter
California-specific demand letter components
1
Header & California jurisdiction
Identify the incident occurred in California, cite California law (Civil Code § 1714), and note the California 2-year statute of limitations (Code Civ. Proc. § 335.1). If public property, note Government Claims Act deadline.
2
Incident narrative with Ortega hooks
Detailed description of fall with explicit attention to inspection failures: no warning cones, no recent sweep logs, no employee presence, recurring spill area.
3
Duty under Rowland and Civil Code § 1714
Explain California's general duty of reasonable care applies to all property owners. Cite Rowland factors showing injury was foreseeable and preventable.
4
Breach: Ortega constructive notice argument
Argue store breached duty by failing to maintain reasonable inspection procedures. Point to lack of sweep logs, inadequate inspection frequency, or no documentation of employee presence.
5
Causation and comparative fault
Explain hazard directly caused your fall. Anticipate and rebut comparative negligence arguments (distraction, obvious hazard). California uses pure comparative negligence—your fault reduces recovery but does not bar it.
6
Economic damages: California billing issues
List medical bills with awareness of Howell/Sanchez rule: you can recover only amounts actually paid or incurred, not full billed amounts if insurance covered treatment. Provide itemized billing and proof of payment/out-of-pocket.
7
Non-economic damages and venue
Pain-and-suffering damages. Note California venue (Los Angeles, San Francisco, San Diego, etc.) and typical jury verdict ranges for similar injuries in that venue.
8
Settlement demand and litigation threat
State your demand. Reference that California slip and fall cases are routinely tried before juries, and cite recent California verdicts in similar cases to show trial exposure.
California statute of limitations: Personal injury claims in California must be filed within 2 years of the injury date (Code Civ. Proc. § 335.1). If the fall occurred on government property (city sidewalk, county building, state park), you must first file a Government Claim with the relevant government entity within 6 months of injury (Government Code §§ 911.2, 945.6).
California settlement factors and venue realities
How California adjusters evaluate slip and fall cases
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Liability clarity
Clear Ortega failure (no sweep logs, obvious inspection gap) increases value. Disputed notice or strong comparative fault (phone distraction, obvious hazard) decreases value.
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Injury severity
Fractures with surgery: $75K-$500K+. Sprains/strains with PT: $10K-$50K. Bruises only: minimal. Permanent limitations significantly increase value.
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Venue
Los Angeles, San Francisco, Alameda County: higher verdicts, plaintiff-friendly. Inland Empire, Central Valley, rural counties: more conservative, lower verdicts.
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Medical billing (Howell rule)
California plaintiffs recover only amounts actually paid or incurred, not full billed charges. Adjusters heavily discount billed amounts and focus on paid amounts.
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Plaintiff credibility
Clean background, consistent story, prompt treatment, no prior claims: higher value. Criminal history, inconsistent statements, treatment gaps: lower value.
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Evidence quality
Photos of hazard, incident report, surveillance video, witness statements: strong case. No photos, no witnesses, delayed treatment: weak case.
California settlement timelines
1
Demand to initial response: 2-4 weeks
California insurers typically acknowledge demand and request additional documentation (medical records, wage verification, incident details).
2
Investigation and Ortega analysis: 30-60 days
Adjuster reviews sweep logs, interviews employees, analyzes video. California adjusters specifically evaluate Ortega constructive notice arguments and whether store can show reasonable inspections.
3
First offer: 2-3 months
Initial offer typically lowball (30-50% of demand). California adjusters heavily discount based on comparative fault, Howell billing limitations, and venue.
4
Negotiation: 3-6 months total
Multiple rounds of demands and counteroffers. California cases often settle in mediation (after lawsuit filed) rather than pre-suit.
5
Lawsuit and mediation: 12-18 months
If pre-suit settlement fails, file in California Superior Court. Discovery (6-9 months), then mediation. Most California premises cases settle at mediation.
California mediation culture: California slip and fall cases rarely go to trial. After lawsuit is filed and discovery (depositions, interrogatories, requests for production) is exchanged, parties attend mandatory mediation. Most California premises cases settle at mediation or shortly after.
Slip and falls on California government property

If your slip and fall occurred on government property (city sidewalk, county building, state park, transit station, public school, courthouse), you must comply with California's Government Claims Act before filing a lawsuit.

Government Claims Act: 6-month deadline

California Government Code §§ 911.2 and 945.6 require you to file a written claim with the government entity within 6 months of the injury. This is a strict deadline; missing it permanently bars your claim.

Critical deadline: You have only 6 months from the date of your fall to file a Government Claim if the property is owned or maintained by a city, county, state agency, school district, or other government entity. This deadline is shorter than the 2-year statute of limitations for private property falls.
What government entities in California control
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City property
Public sidewalks, city parks, libraries, city hall, municipal parking lots. File claim with city clerk or risk manager.
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County property
Courthouses, county buildings, county parks, health facilities. File with county clerk or county counsel.
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Transit agencies
BART, Muni, Metro, bus stations, transit platforms. File with agency's claims administrator.
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School districts
Public schools, school parking lots, playgrounds, athletic fields. File with district superintendent or business office.
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State property
State parks, Caltrans roads, state buildings, universities. File with California Victim Compensation Board (if state entity).
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Special districts
Water districts, sanitation districts, community services districts. File with district's governing board or general manager.
How to file a California Government Claim
1
Identify the correct entity
Determine whether city, county, state, school district, or special district owns or maintains the property where you fell.
2
Obtain Government Claim form
Most entities provide a standard claim form on their website. You can also use a general Government Code § 910 claim form.
3
Describe the incident and demand
Include date, time, location, description of hazard, your injuries, and the amount you are claiming (medical bills, lost wages, pain-and-suffering).
4
File within 6 months
Mail or hand-deliver the claim to the entity's clerk, risk manager, or claims office. Get proof of filing (certified mail receipt or date-stamp).
5
Wait for response
Entity has 45 days to respond. If they deny your claim or fail to respond, you receive a rejection notice and can then file a lawsuit in Superior Court.
Late claim applications: If you miss the 6-month deadline, you may file a late claim application within 1 year, but approval is discretionary and requires showing you had a valid excuse for missing the deadline (e.g., minor, incapacitated, unaware it was government property).
How I handle California slip and fall demand letters

I personally draft and negotiate California slip and fall demand letters for clients injured at stores, restaurants, malls, parking lots, and public property throughout California. These cases require detailed knowledge of California premises liability law, Ortega constructive notice arguments, and California settlement dynamics.

Services for California slip and fall claimants
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Ortega liability analysis
I analyze whether you can establish constructive notice under Ortega by showing the store failed to maintain reasonable inspection procedures.
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Evidence preservation & spoliation letters
I send immediate preservation demands for surveillance video, sweep logs, employee schedules, and incident reports before they're destroyed.
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California-specific demand drafting
I prepare demands citing Civil Code § 1714, Rowland factors, Ortega constructive notice, CACI instructions, and California venue-specific verdict data.
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Government Claims Act compliance
If your fall occurred on city, county, or state property, I prepare and file the Government Claim within the 6-month deadline to preserve your right to sue.
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Settlement negotiation
I negotiate directly with California insurance adjusters, countering lowball offers with Ortega arguments, venue data, and medical documentation.
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California litigation & mediation
If settlement fails, I file in California Superior Court, conduct discovery (depositions, interrogatories, document requests), and represent you at mediation and trial.
Injured in a California slip and fall?
I handle California slip and fall demand letters and premises liability claims personally.
Email: owner@terms.law
Frequently asked questions about California slip and fall claims

Under Ortega v. Kmart, you don't need to prove exactly how long the hazard existed. Instead, you can establish constructive notice by showing the store failed to implement reasonable inspection procedures.

How to use Ortega:

  • Request the store's sweep logs for the area where you fell
  • If they can't produce logs showing recent inspections, argue they failed to maintain reasonable procedures
  • Point to inadequate inspection frequency given the nature of the business (e.g., grocery produce section should be inspected more frequently than a shoe aisle)
  • Show lack of employee presence in the area

If the store cannot show it had and followed reasonable inspection policies, a California jury may infer the hazard was present long enough to be discovered.

Private property: 2 years from the date of your fall (Code of Civil Procedure § 335.1).

Government property: You must file a Government Claim with the government entity within 6 months of your fall (Government Code §§ 911.2, 945.6). After your claim is denied, you have 6 months to file a lawsuit.

Critical difference: The 6-month Government Claims Act deadline applies to any fall on property owned or maintained by a city, county, state agency, school district, transit authority, or other government entity. Missing this deadline permanently bars your claim.

If you're unsure whether the property is government-owned, consult an attorney immediately to preserve your rights.

California's Howell v. Hamilton Meats rule limits your economic damages to the amounts actually paid or incurred for medical treatment, not the full billed charges.

Example: Hospital bills $50,000 for your treatment. Your health insurance pays $12,000 as the contracted rate. Under Howell, you can recover $12,000 in economic damages, not the full $50,000 billed amount.

Why this matters in demand letters:

  • California adjusters heavily discount billed amounts and focus on paid amounts
  • Your demand should list both billed and paid amounts, but emphasize paid/incurred
  • Attach payment records, EOBs (explanation of benefits), and proof of out-of-pocket expenses
  • Non-economic damages (pain-and-suffering) are not affected by Howell and remain separately recoverable

Yes. California applies pure comparative negligence, which reduces your recovery by your percentage of fault but does not bar recovery entirely.

How it works: If a jury finds you 30% at fault (e.g., you were looking at your phone when you fell), your damages are reduced by 30%. If your damages are $100,000, you recover $70,000.

Common comparative fault arguments:

  • You failed to watch where you were walking
  • The hazard was open and obvious
  • You ignored warning signs or cones
  • You were distracted by your phone or conversation
  • You were wearing inappropriate footwear

Defense strategies: Anticipate these arguments in your demand letter and rebut them (hazard was not obvious, you were engaged in reasonable activity like reading product labels, store's failure to inspect was primary cause).

California venues vary significantly in their friendliness to slip and fall plaintiffs. Urban, plaintiff-friendly counties tend to produce higher verdicts and settlements.

Plaintiff-friendly venues:

  • Los Angeles County: Large, diverse jury pool; history of substantial premises verdicts
  • San Francisco County: Very plaintiff-friendly; high pain-and-suffering awards
  • Alameda County: Oakland and Berkeley; sympathetic to injured plaintiffs
  • San Diego County: Moderate to plaintiff-friendly; substantial verdicts in clear liability cases

Defense-friendly venues:

  • Inland Empire (Riverside, San Bernardino): More conservative; lower verdicts
  • Central Valley (Fresno, Kern, Tulare): Defense-friendly; skeptical of slip-and-fall claims
  • Rural Northern California counties: Small, conservative jury pools; lower damages

California adjusters evaluate venue when setting settlement authority. A case in Los Angeles or San Francisco will settle for significantly more than the same case in Fresno or Riverside.

Generally, no. California follows the "American rule" that each party pays their own attorney fees unless a statute or contract provides otherwise.

Exceptions:

  • Code of Civil Procedure § 998 offers: If defendant rejects a reasonable settlement offer and plaintiff wins more at trial, plaintiff may recover post-offer costs (but not attorney fees)
  • Bad faith or fraud: In rare cases involving intentional misconduct, punitive damages or fee-shifting may apply
  • Government defendants: Some government claims statutes allow limited fee awards

Most California slip and fall cases are handled on contingency: attorney receives a percentage of recovery (typically 33%-40%), and you pay nothing unless you win.