Farmers Ins. Exchange v. State of California

In Farmers Ins. Exchange v. State of California (1985) 175 Cal.App.3d 494, the plaintiff insurance companies sought damages for automobile paint corrosion caused by the state's pesticide spraying for medfly eradication. Rejecting the plaintiffs' argument that Civil Code section 3482 did not apply because the law at issue "did not 'expressly authorize' the state to damage automobile paint finishes," the appellate court stated: "This misses the point. The authorizing statute need not predict the precise nature of the damages. It need only authorize the governmental action." (175 Cal.App.3d at p. 503.)