In Hirsch v. Department of Motor Vehicles (1974) 42 Cal.App.3d 252, the plaintiff purchased an automobile from the person identified as owner on the ownership certificate which the department had issued. In fact, the car had been stolen and the department had been negligent. The action against the department to recover damages was based on negligence, and the department's demurrer was sustained upon the immunity found in Government Code sections 818.4 and 821.2 for issuance of "any permit, license, certificate," etc. The appellate court affirmed the dismissal upon that ground, and then added this (at p. 258): "Further, quite aside from sections 818.4 and 821.2, the certificate of ownership here issued can clearly be construed as a 'misrepresentation' by the Department of Motor Vehicles of the true ownership of the vehicle, falling within the purview of section 818.8; thus defendant would be entitled to immunity under that section alone."