Recently the court allowed CalFire to recover fire suppression and investigative costs from anyone who starts a fire, including a corporation’s whose agent’s negligently start a fire.  Presbyterian Camp and Conference Centers, Inc. v. Superior Court (2019) 42 Cal.App.5^th 148.  This case conflicts with a 2017 ruling that held a corporation is not vicariously liable for a fire started negligently by an employee.  Department of Forestry & Fire Protection v. Howell (2017) 18 Cal.App.4^th 154.  As a result, there is a split in authority over corporate liability for fire suppression costs.  This issue will need resolved as fire liability is an ongoing issue.