MA and CA do drop testing of handguns. I see no CZ of any model on MA's list of approved handguns. I assume this is because CZ did not provide guns to be tested, rather than their guns failing the test. The CZ 83 chambered in .380 Auto with a glossy blue finish is on CA's list, which means it passed the drop test. I see no reason why a CZ 83 chambered in .32 Auto would fair differently.
I have read a report of a guy who dropped his CZ 82 barrel pointing upward onto his driveway, which resulted in it firing. The gun was in condition 2. You will note pulling back on the slide of a CZ 82/83 with hammer down will result in the protruding rear of the firing pin contacting the hammer. If the gun is dropped barrel pointing upward from sufficient height slide momentum could apparently cause the firing pin to be struck hard enough to ignite the cartridge primer.
Three specimens of glossy blue CZ 83s chambered in .380 Auto passed the CA drop test, which occurs from a height of 1.1 m (39.8 in, roughly waist height) onto concrete. One of the drop configurations is barrel pointing upward. Perhaps the gentleman whose CZ 82 fired upon dropping dropped it from a greater height. I carry my CZs and Beretta in condition 1 so the 82/83 design flaw doesn't affect me.
