In Dole Citrus v. State of California

In In Dole Citrus v. State of California (1997) 60 Cal.App.4th 486, the State did not lose design immunity when it updated design standards requiring screens on new overpasses and existing dangerous overpasses. (Ibid.) There, the plaintiff failed to show that the unscreened overpass created a dangerous condition that caused the plaintiff's injury: a car accident resulting from a jumper's contact with the plaintiff's car. (Ibid.) The State did not lose design immunity because general design improvements did not constitute an admission that the prior design was defective. (Id. at p. 494.) Rather, the new requirements were interpreted as an alternative to the prior design in future construction. (Ibid.)