In Brown v. Poway Unified School District (1993) 4 Cal.4th 820, the plaintiff did not challenge the determination in the trial court that the defendant school district could not be liable under section 835, subdivision (b), because there was no evidence the district had notice of the allegedly dangerous condition -- lunch meat on a hallway floor that caused Brown to slip and fall while delivering computers to a school facilities building. (Poway, supra, 4 Cal.4th at pp. 823-824.) Rather, the plaintiff argued the doctrine of res ipsa loquitur applied on the facts of his case and created a presumption of negligence establishing a prima facie case under section 835, subdivision (a). (Poway, at p. 825.) The Supreme Court reversed, holding that a plaintiff could not use res ipsa loquitur to establish a prima facie case against a public entity defendant under section 835, subdivision (a). (Poway, at pp. 828-829.) The Supreme Court also held the facts of the case did not satisfy the requirements of the res ipsa loquitur doctrine. (Poway, supra, 4 Cal.4th at p. 828.) "The res ipsa loquitur presumption, under California law, is that 'a proximate cause of the occurrence was some negligent conduct on the part of the defendant . . . .' (Evid. Code, 646, subd. (c)(1).) Thus, if the Legislature had intended to hold a public entity liable for all types of negligent conduct by public employees, we would have little hesitation in holding that res ipsa loquitur satisfied the statutory conditions of liability. However, it appears that the Legislature intended to impose liability on public entities only in a narrow set of cases. The narrowing of liability is accomplished by the requirement than an employee of the public entity have 'created' the dangerous condition. ( 835, subd. (a).)" (Poway, supra, 4 Cal.4th at pp. 832-833.) "The term 'created' must be defined as the sort of involvement by an employee that would justify a presumption of notice on the entity's part." (Id. at p. 836.) The Poway Court's review of reported decisions applying section 835, subdivision (a), reflected "cases in which public employees actively created dangerous conditions under circumstances that would clearly justify a presumption of notice on the part of a public employer. . . .In cases such as these, a public employee's involvement in creating the dangerous condition provides a basis for presuming that the public entity has notice of the condition. This is because a public entity is presumed to have knowledge of a dangerous condition that is the 'natural and probable consequence' of its work. " (Poway, supra, 4 Cal.4th at p. 837.) The California Supreme Court confirmed that section 835, subdivision (a) was intended to incorporate the rule of Fackrell and Pritchard because "'the creation by the public entity of a physical facility or condition that is "dangerous" dispenses with the necessity of notice, for the entity presumably knows already that it has affirmatively created the condition, and thus has notice that it is dangerous.'" (Brown, supra, 4 Cal.4th at p. 836.) "Because an entity must act through its employees, virtually all suits brought on account of dangerous conditions created by the entity will be brought under subdivision (a) of section 835. In contrast, subdivision (b) can also support suits based on dangerous conditions not created by the entity or its employees." (Brown, supra, at p. 836.)