California attorney · CA Bar #279869

California premises liability attorney

I'm Sergei Tokmakov, a California attorney. If you were injured on someone else's property in California, Civil Code § 1714 imposes a general duty of care and the Rowland v. Christian factors decide whether the property owner breached that duty. I write the pre-suit memo or the attorney demand letter that maps the duty-breach analysis to your facts.

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Cal. Civ. Code § 1714
Quick answer

California premises liability is built on Civ. Code § 1714 (general duty of care) refined by Rowland v. Christian (1968) 69 Cal.2d 108, which abolished the old invitee/licensee/trespasser distinctions and replaced them with a multi-factor balancing test. Dog bites in California are strict liability under Civ. Code § 3342, with no "one bite rule." Negligent-security cases trace foreseeability to Ann M. v. Pacific Plaza Shopping Center (1993) 6 Cal.4th 666. The SOL is two years under CCP § 335.1; government-owned property triggers the Gov. Code § 911.2 six-month written-claim deadline. Pre-suit memo from $349 / attorney demand letter from $575.

2-year SOL
Under CCP § 335.1
Notice
Actual or constructive required
Comparative
Plaintiff fault reduces, not bars
Fees
Contingency for serious matters

What I do for premises liability matters

1

Build the notice case (actual or constructive).

Premises cases turn on notice. I plead actual or constructive notice with the specific maintenance history, prior complaints, and inspection records so the defendant cannot fight on knowledge.

Rowland v. Christian
2

Anchor the discovery on maintenance records.

I draft the demand to telegraph the discovery angle, maintenance logs, inspection records, prior incident reports, and staffing records, so the defendant knows what is coming.

3

Frame comparative fault favorably.

California's pure comparative-fault rule means plaintiff fault reduces but does not bar recovery. I frame the comparative-fault analysis favorably in the demand so the carrier does not anchor on plaintiff conduct.

4

Hand off to a contingency firm.

The memo is the intake document for plaintiff-side premises firms. They sign serious matters on contingency. I write it so the firm sees the notice case, the damages, and the comparative-fault posture in one pass.

Why this calls for an attorney, not a pro se claim

DIY / template

What a self-written letter misses

  • Cannot prove notice (actual or constructive)
  • Misses the maintenance-records discovery angle
  • Lets the defendant control the inspection narrative
  • Ignores comparative-fault apportionment
Attorney letter

What the attorney letter does

  • Pleads notice with the specific maintenance history
  • Anchors discovery on inspection and complaint records
  • Frames comparative fault favorably to the plaintiff
  • Hands the file to a contingency firm with the timeline locked

Premises cases turn on notice, the memo answers whether the defendant knew or should have known in time to fix the condition.

The controlling law

The fact pattern that wins. A grocery-store slip-and-fall where the store had video of a spill present for two hours before the fall, no warning cones, no employee inspection log showing the aisle was checked: Rowland foreseeability and breach are both strong. Combine with a documented broken-ankle injury, $35,000 in medicals, and a comparative-fault story that holds up (proper footwear, no distraction, no warning sign visible), and the case is a contingency-firm candidate at a real settlement multiplier. The attorney letter or memo identifies which Rowland factors are strongest before the negotiation starts.

What clients send me

Premises-liability cases live or die on documentation. The strongest demand letter or memo is built from these documents:

  • Photographs of the hazard at the time of the incident (cell-phone photos with timestamps, scene photos)
  • Incident reports filed with the property owner, store manager, or building security
  • Names and contact information for the property owner, occupier, or operator (and the registered agent if it's an entity)
  • Surveillance video request (preservation letter is the urgent first step; video is often deleted within 30 days)
  • Police report if law enforcement responded (dog bites, assaults on premises, falls requiring transport)
  • Medical records for treatment connected to the injury (ER, urgent care, primary care, specialists, PT)
  • Photographs of visible injuries (especially in the days following)
  • Witness names and contact information if any are available
  • Medical bills for treatment received
  • Lost-wages documentation: pay stubs, W-2s, employer letter on missed time
  • Any communications you have already had with the property owner, store manager, or insurer (do not give recorded statements without an attorney)
  • For dog-bite cases: owner's name and address, dog's breed and known history, animal-control report
  • For negligent-security cases: any reports of prior similar incidents on the property (police reports, news articles, tenant complaints)

If records are incomplete, send what you have. I tell you what is missing and whether the gaps affect the memo before quoting.

What I send back

$349

Premises Liability Pre-Suit Memo

  • Written legal memo (6-12 pages)
  • Rowland factor-by-factor analysis
  • SOL + defenses + damages framework
  • Settlement valuation range
  • Referral recommendation if appropriate
  • Standard turnaround 7-10 business days

How the engagement runs

1
Send facts

Email a paragraph + key documents.

2
Identify theory

I map the facts to the CA statute.

3
Draft letter

Attorney letter on letterhead.

4
You approve

Two revision rounds included.

5
Send certified

USPS certified + email delivery.

6
Negotiate

Three negotiation responses included.

Choose your path

Start here if

Case memo

$349
  • You want a written legal evaluation first
  • You may refer to a contingency firm later
  • Statute or evidence questions are unsettled
Accept memo - $349
Start here if

Demand + draft lawsuit

$1,200
  • Counterparty needs to see the lawsuit is real
  • Multiple claims or institutional defendant
  • You may file pro se after the demand
Accept package - $1,200

Pricing

Premises Liability Pre-Suit Memo

$349 · flat fee
  • Written legal memo (6-12 pages)
  • Rowland factor-by-factor analysis
  • SOL + defenses + damages framework
  • Settlement valuation range
  • Referral recommendation if appropriate
  • Standard turnaround 7-10 business days

Frequently asked questions

You
What is California premises liability?
S
Premises liability is the area of California negligence law that holds property owners and possessors responsible for injuries on their land. It is built on Civ. Code § 1714's general duty of care, refined by Rowland v. Christian (1968) 69 Cal.2d 108, which abolished the old common-law distinctions between invitees, licensees, and trespassers in favor of a multi-factor balancing test that asks whether the defendant exercised reasonable care under all the circumstances. Common premises-liability cases include slip-and-fall, trip-and-fall, dog bites, swimming-pool injuries, falling-object injuries, fires, electrical hazards, and negligent security on commercial property.
You
What are the Rowland v. Christian factors?
S
Rowland v. Christian (1968) 69 Cal.2d 108 sets out the multi-factor test California courts use to decide whether a property owner owed and breached a duty of care: (1) foreseeability of harm to the plaintiff, (2) degree of certainty that the plaintiff suffered injury, (3) closeness of the connection between defendant's conduct and the injury, (4) moral blame attached to the conduct, (5) policy of preventing future harm, (6) burden on the defendant and the community of imposing a duty, and (7) availability and cost of insurance. The factors apply to most premises cases and are how California courts actually decide duty-breach questions.
You
How does California dog-bite law work?
S
Cal. Civ. Code § 3342 imposes strict liability on dog owners for bites in public places or while the bite victim is lawfully on private property (including the owner's property). California does not have a "one bite rule." The owner is liable regardless of whether the dog has bitten before and regardless of whether the owner knew the dog was dangerous. The strict-liability framework applies to bites; non-bite injuries (a dog knocking someone down) fall under general negligence under Civ. Code § 1714. Renters insurance and homeowners insurance usually cover dog-bite liability with policy limits in the $100,000 to $300,000 range.
You
What is the statute of limitations for premises liability?
S
CCP § 335.1 sets a two-year statute of limitations for premises-liability cases, running from the date of injury. Government-owned property triggers the Gov. Code § 911.2 six-month written-claim presentation requirement (city sidewalk, state highway, public school, transit district). Missing the government-claim deadline almost always bars the case, with very narrow late-claim relief. Minors generally toll until age 18 under CCP § 352. The memo runs the calendar math first because the wrong calendar kills the case.
You
What is negligent security?
S
Negligent security is a sub-category of premises liability where the property owner failed to provide reasonable security measures, leading to a foreseeable third-party criminal act (assault, robbery, sexual assault, shooting) that injured a tenant, guest, or invitee. The leading California case is Ann M. v. Pacific Plaza Shopping Center (1993) 6 Cal.4th 666, which set out the foreseeability framework: prior similar incidents on or near the property typically establish foreseeability and trigger a duty to provide reasonable security. Common defendants are apartment complexes, hotels, parking lots, shopping centers, and bars.
You
What in the $349 memo versus the $575 demand letter?
S
The $349 memo is a written legal evaluation: it applies the Rowland factors to your fact pattern, calendars the CCP § 335.1 SOL (or Gov. Code § 911.2 government-claim deadline), assesses likely defenses (comparative fault, open-and-obvious, assumption of risk), and gives a damages framework and rough settlement valuation. The $575 demand letter goes to the property owner's insurer with the legal theory laid out and a specific settlement demand on attorney letterhead. The right product depends on case posture: if you have not yet contacted the carrier, the demand letter is usually the right next move. If you need to know whether the case has legs first, the memo is the right starting point.
You
What about open-and-obvious hazards?
S
California recognizes the open-and-obvious doctrine but has narrowed it significantly. Under Kentucky Fried Chicken of California v. Superior Court (1997) 14 Cal.4th 814 and follow-up cases, a property owner can argue that a hazard was so obvious that the plaintiff should have avoided it, which can defeat the duty element. But the doctrine is not absolute: if the property owner anticipated that the plaintiff might encounter the hazard despite its obviousness (because of distraction, necessity, or because there is no reasonable alternative path), the duty remains. The memo addresses whether open-and-obvious is likely to be raised and how strong the defense is on your facts.
You
What is comparative fault under Prop. 51?
S
California follows pure comparative fault, meaning the plaintiff's recovery is reduced by their percentage of fault but is not barred even at high percentages. Proposition 51 (Civ. Code § 1431.2) layered on non-economic-damages proportionality: each defendant pays only their proportionate share of pain and suffering. Common premises defenses argue plaintiff was distracted, intoxicated, wearing inappropriate footwear, or otherwise contributed to the fall. The memo addresses likely fault-allocation arguments and how they affect case math.
You
Do you handle property-owner-side defense?
S
Most of my premises-liability work is plaintiff-side because Civ. Code § 1714 and the Rowland factors are how an injured person gets to recovery. I do occasionally write defense memos for property owners (or their insurers when the carrier wants outside counsel for a position memo) on whether liability is realistic and how to frame the defense. If you are a property owner with notice of a claim, email me the file and I will tell you whether the defense memo is the right fit before quoting.
You
When should I call a contingency PI firm instead?
S
If your premises-liability case has significant medical bills (over $25,000), lost wages, and a clear liability theory, a contingency-fee plaintiff-side PI firm is the right home for the case. They take it on contingency, absorb the expert costs, and run the litigation. The memo I write becomes their intake document. For smaller cases that contingency firms decline (typical floor around $15,000 settlement value), I can draft the $575 attorney demand letter directly and the negotiation runs from there. The intake conversation determines which path fits the facts.

Hurt on someone else's property? Let me map the case.

Email me a short paragraph about where, when, and what happened. I'll respond same day with a scoped flat-fee quote.

Email owner@terms.law