How have courts treated the issue of street lighting in cases involving pedestrians?

In Plattner v. City of Riverside (1999) 69 Cal.App.4th 1441, 1445, where the accident occurred in a cross-walk and involved a car and a pedestrian, the court noted that, other than the lack of a light, the plaintiff had not shown that there was anything dangerous about the cross-walk. The court went on to make the cogent observation that "darkness is a naturally occurring condition that the city is under no duty to eliminate." (Ibid.)

In City of San Diego v. Superior Court (2006) 137 Cal.App.4th 21, 31, the court concluded that streets lights were a "preventative safety measure" and the lack of street lighting "does not describe a defective physical condition any more than would an entity's failure to provide adequate lights to assure assaults do not take place at a highway rest stop."