The trial court properly dismissed this personal injury suit by a bicyclist against Orange County under Gov. Code 831.4 which provides government entities absolute immunity from suit for injuries sustained while engaged in bike riding or while on a bike trail. Plaintiff was injured when he rode his bike into a fence separating two parts of a bike trail. The fence had recently been changed from log rails between posts to wire strung between the posts. Plaintiff didn’t see the wire and tried, unsuccessfully, to ride between the posts. The fence was an integral part of the trial, and the trail immunity covered the design of the fence as well as the rest of the trail.

Though the defendant did not appear and defaulted, it did not thereby waive any objection to personal jurisdiction.  A trial court may and should determine its own subject matter and personal jurisdiction before entering a default judgment to assure that it is not a void decree.  Here, the trial court properly gave plaintiff notice of its doubt that it had jurisdiction, giving plaintiff an opportunity to present evidence and argument on the subject before ruling.  The trial court correctly held that it lacked personal jurisdiction over Al Shabaab.  That organization is not “at home” in the United States and so is not subject to general personal jurisdiction here.  Al Shabaab’s few known contacts with California had no connection with the attack on a hotel abroad during which plaintiff’s decedent was killed.  So California also lacked specific personal jurisdiction over Al Shabaab.