Falling Pipe Child Injury
In Ornelas v. Randolph (1993), a minor was injured by a falling pipe while playing on old farm equipment on private land. Section 846 barred the minor's suit against the landowner.
The court said, "the landowner's duty to the nonpaying, uninvited recreational user is, in essence, that owed a trespasser under the common law as it existed prior to Rowland v. Christian (1968) 69 Cal. 2d 108 [70 Cal. Rptr. 97, 443 P.2d 561, 32 A.L.R.3d 496]; i.e., absent willful or malicious misconduct the landowner is immune from liability for ordinary negligence." ( Ornelas v. Randolph, supra, 4 Cal. 4th at p. 1100.)