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.5th 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.4th 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.