California, United States of America
The following excerpt is from Massa v. Southern Cal. Rapid Transit Dist., 43 Cal.App.4th 1217, 51 Cal.Rptr.2d 164 (Cal. App. 1996):
Government Code section 905 provides, "there shall be presented in accordance with Chapter 1 and Chapter 2 of this part all claims for money or damages against local public entities " (emphasis added) and Government Code section 950.2 requires that, "a cause of action against a public employee or former public employee for injury resulting from an act or omission in the scope of his employment as a public employee is barred if an action against the employing public entity for such injury is barred under Part 3 of this division or under Chapter 2 of Part 4 of this division." This statute has been interpreted to require that, prior to bringing an action against a public employee, the plaintiff must comply with Government Code section 900 et seq. (Williams v. Townsend (D.C.Cal.1968) 283 F.Supp. 580.)
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