California, United States of America
The following excerpt is from Crow v. State of California, 222 Cal.App.3d 192, 271 Cal.Rptr. 349 (Cal. App. 1990):
Under the Tort Claims Act, 1 "There shall be presented in accordance with Chapter 1 [ 900 et seq.] and Chapter 2 [ 910 et seq.] of [Part 3] all claims for money or damages against the state: ... (c) For money or damages (1) on express contract, or (2) for an injury for which the state is liable." ( 905.2; see also 905.) Thus, although actions arising out of contract are not affected by the immunities and liabilities in part 2 of the Tort Claims Act ( 814), they are nonetheless subject to its procedural requirements. (White v. State of California (1987) 195 Cal.App.3d 452, 477, 240 Cal.Rptr. 732; Loehr v. Ventura County Community College Dist. (1983) 147 Cal.App.3d 1071, 1079, 195 Cal.Rptr. 576.) It goes without saying that any tort cause of action must similarly meet this requirement.
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