How have courts interpreted section 19 of the California Code of Civil Procedure on liability for property damaged by the construction of a public improvement?

In Albers v. County of Los Angeles (1965) 62 Cal.2d 250, 42 Cal.Rptr. 89, 398 P.2d 129, this court, again considering the effect of the words "or damaged" in section 19, held that the owner of property abutting a public improvement was entitled to compensation where the property was damaged as a result of the construction of that public improvement. In Holtz v. Superior Court (1970) 3 Cal.3d 296, 90 Cal.Rptr. 345, 475 P.2d 441, we referred to our decision in Albers as follows: "In announcing our holding in Albers ..., we did not overlook the competing considerations which caution against an open-ended, 'absolute liability' rule of inverse condemnation. Recognizing that 'fears have been expressed that compensation, allowed too liberally, will seriously impede, if not stop, beneficial public improvements because of the greatly increased cost' [citation], we deemed it prudent to focus our policy inquiry on situations which shared a general [10 Cal.4th 383] factual similarity with that present in Albers. Thus we limited our holding of inverse condemnation liability, absent fault, to 'physical injuries of real property' that were 'proximately caused' by the improvement as deliberately constructed and planned." (Id. at pp. 303-304, 90 Cal.Rptr. 345, 475 P.2d 441, italics added, fn. omitted.)