Can a landowner be held liable for damage caused by a wind that blows large quantities of sand onto his property?

6 To reach its result, the court analogized to the case of Stewart v. Birchfield (1911) 15 Cal.App. 378, 114 P. 999, where an adjoining landowner cleared his property of brush and left it unirrigated. Winds blew large quantities of sand onto plaintiff's property. This case is cited in discussions of liability for natural conditions, however, the decision is actually based on a theory of reasonable use. " 'Every man may use his own land for all lawful purposes to which such lands are usually applied, without being answerable for the consequences; provided he exercises ordinary care and skill to prevent any unnecessary injury to the adjacent land owner ' " (Id., at p. 381, 114 P. 999.) The court found that the defendant had a right not only to clear the ground but to leave it uncultivated. The right was incident to ownership and did not create liability unless the activity itself was negligent.