In Ma v. City and County of San Francisco (2002) 95 Cal. App. 4th 488, the First District Court of Appeal determined that, based on common law tort principles rather than statute, San Francisco owed a duty of care to citizens using its 911 emergency service. The Ma court also decided that the qualified immunity provided by section 1799.107 does not apply to 911 dispatching because 911 dispatching does not come within the statutory definition of "emergency services." Finally, Ma held the discretionary immunity afforded by Government Code section 820.2 does not apply to 911 dispatching.