By: Lorenzo Blanco
Volume X – Issue II – Spring 2025
I. INTRODUCTION
On the morning of January 7th, 2025, residents of the Pacific Palisades woke up to the faint smell of smoke aloft in the air. As a dark cloud of smoke rose ominously into the Los Angeles sky, January 7th would become a day unlike any other. By the early afternoon, the Pacific Palisades fire had grown so rapidly that fire officials put a mandatory evacuation into place all the way from the fire’s origin in the mountains down to the water’s edge on the Pacific Coast Highway. [1] Yet as the Palisades blaze raged on, Southern California’s infamous Santa Ana winds of 50-80 miles per hour that night [2] sparked a series of menacing fires around the Los Angeles area. That evening at precisely 6:18 pm however, another towering dark plume of smoke rose out of the mountains of the Eaton Canyon Natural Area in Altadena. As day turned to dusk, the two fires grew to unprecedented size while consuming houses, retirement homes, schools, cars, and anything or anyone else in their paths. Community members fled in horror while firefighters scrambled to respond to the two most destructive wildfires in Los Angeles history. [3] In the coming days, residents could only watch in disbelief as the Santa Ana winds prevented any containment of the Palisades and Eaton fires. Weeks passed by with both fires still not fully contained. By the time the fires had been definitively quelled, in addition to the property damaged in the other six fires across Los Angeles, the Palisades and Eaton fires had burned a total of 5,449 homes to the ground [4] and claimed the lives of at least 29 people. [5] Residents speaking out on their hardships have begun to uncover deeply concerning oversights in emergency preparedness and fire response strategies from the California state government, the avoidant legal strategies of private insurance companies, and even power companies’ potential culpability in the ensuing disasters
II. LIABILITY DUE TO NEGLIGENCE: SITUATIONAL STRESSORS IN LOS ANGELES AND ESSENTIAL LEGAL QUESTIONS
As Los Angeles scrambles to rebuild, residents affected by the wildfires are left searching for answers to a plethora of questions: how did the Palisades and Eaton fires start? How did these fires reach such extraordinary size? What – or who – could be responsible for their losses? Residents of the Palisades and Altadena communities are left with the monumental task of demanding and successfully arguing for the help they deserve to heal from the devastation. Insurance companies, catching wind of increasing fire risks in what they labeled as “extreme weather conditions,” beginning just two years ago conducted one of the largest waves of policy cancellations the state has ever seen. [6] Citing arbitrary, largely unfounded reasoning like “inadequate roofing” that were in some cases completely out of a policy holder’s control, powerful insurance companies began to cancel or refuse to renew policies across the state. State Farm, California’s largest insurance company, in 2023 dropped 30,000 policies alone. [7] Additionally, those who have lost their homes to the fires face an almost insurmountable challenge of finding new accommodations in a city with a housing cost premium 133.1% above the national average. [8] In such an expensive and competitive housing market, landlords across Los Angeles have been accused of raising rental prices in undamaged neighborhoods by rates as high as 25-50%, a blatant violation of California Penal Code § 396 that caps rent increases to 10% during periods of state-declared emergencies. [9] Angered by these seemingly unfounded and unsubstantiated lines of reasoning employed to justify policy termination and an inhospitable housing market in the wake of disaster, homeowners in Southern California have begun to retaliate through legal action in an effort to recover their losses. Consequently, residents must evaluate and determine the best legal strategy to be awarded the damages they so desperately need. In the context of the Palisades and Eaton fires, questionable conduct on the part of Los Angeles County and Southern California Edison in particular have raised ample concern of negligence amongst Los Angeles residents affected by the wildfires. Though the particular defendants and instances of negligence differ between the cases of the Palisades and Eaton fires, the constant remains in what plaintiffs affected by either fire must prove: the existence of a legal duty the defendant owes to the plaintiff who filed suit, a clear breach of that duty on the part of the defendant, a demonstrated and remediable harm caused by the defendant’s breach of their legal duty to the plaintiff, clear evidence that the defendant’s conduct is the proximate cause of the harm inflicted on the plaintiff, and finally that the defendant’s conduct is the “cause-in-fact of harm to the plaintiff.” [10] In California, a defendant’s conduct qualifies as proximate cause when there is a “legally recognized connection between a harmful act and the resulting harm” upon the plaintiff. [11] Set as precedent in the 1929 Thompson v. Pacific Electric Railway case and clarified by the California Supreme Court in the 1991 case of Mitchell v. Gonzales, defendant conduct is considered proximate cause in accordance with the substantial factor test when “a reasonable person could conclude that it could have contributed to the harm;” furthermore, “such behavior need not be the sole cause of harm.” [12] In accordance with California legal precedent, the “cause-in-fact” or “but for” cause essentially stipulates that the harm would not have happened “but for” the action of the defendant. [13] The individual contexts of the Palisades and Eaton fires have brought negligence litigation to the forefront of California and national legal attention, and the differences between each fire require an individualized examination to determine the efficacy of a negligence lawsuit in successful attainment of damages for Los Angeles residents who have endured unimaginable losses.
III. BACKGROUND ON THE PACIFIC PALISADES AND ALTADENA NEIGHBORHOODS:
Though vastly different in their origins, the Pacific Palisades and Altadena neighborhoods are two foundational pieces in the history and continued legacy of Los Angeles. The Pacific Palisades, founded in 1922 by Methodist parishioners who sought to construct a religious epicenter amidst the ever-growing city [14], became a crucial refuge for German scholars, artists, and thinkers of Jewish descent as the Nazi party began to seize power. [15] As a steadily growing gateway to the Westwood and Beverly Hills neighborhoods of Los Angeles, the Pacific Palisades—known to most Angelenos as simply “the Palisades”—rose to cultural prominence as an important haven for Jewish exiles and therefore a stronghold of German post-war memorial culture. [16] Originally constructed and paved directly through the Palisades, Sunset Boulevard would become one of the most iconic and crucial arteries of West Los Angeles [17] that inspired popular culture for decades to come. The allure of the Palisades’s picturesque, oceanfront scenery would mean that the small town once populated by just 1,000 residents in 1929 [18] would grow to be one of the most desirable, expensive neighborhoods in Los Angeles. [19] However, the Palisades’s breathtaking views atop the Santa Monica Mountains and amidst chaparral wildlands come with a steep fire risk, a heightened risk the neighborhood of Altadena shares. [20]
Nestled in the San Gabriel Mountains just across the City of Los Angeles, Altadena was founded in 1887 by brothers John and Fred Woodbury. [21] Constructed as a suburb for Los Angeles elite, the real estate market crash of 1888 allowed for wealthy business magnates from the Midwest to move in and transform Altadena’s land into farmland, where an extensive network of public transportation allowed for farm owners and other residents to easily access the neighboring Pasadena and other Los Angeles communities. [22] These wealthy, predominantly white business owners would build large estates and vacation homes facing the breathtaking views of Eaton Canyon that attracted even more people to the neighborhood; the population swelled to upwards of 40,000 in the 1940s. [23] By the early 1950s, Altadena’s White residents made up around 96% of its total population. [24] However, the 1960s and 1970s would bring major social change across the country and to Altadena, as the Civil Rights Movement’s successful dismantling of segregation spurred a substantial White flight from the mountain suburb. New residents moving into Altadena were predominantly people of color, and those that remained in the neighborhood embraced the new, diverse influx of residents with community initiatives like the Altadena Community Garden meant to unite residents of varying cultural backgrounds and instill strong bonds across racial differences for generations to come. [25] The Altadena community is particularly significant to Black Angelenos; as one of the only neighborhoods without redlining in the 1960s and 1970s, Black families moving westward across the country were able to buy homes. [26] In 2023, 81% of Black residents of Altadena owned their own homes—almost double the national average. [27]
The cultural significance of the Palisades and Altadena neighborhoods to Angelenos of myriad backgrounds has undoubtedly made these communities some of the most cherished within Los Angeles. It is apparent that the devastation of the Pacific Palisades and Altadena neighborhoods represents far more than the increased risk to property and resources in a drought-stricken, fire-prone chapparal climate. The buildings lost to each fire were pieces of each community’s history; houses were the physical ties to multigenerational legacies while common businesses, schools, and places of worship united people across ethnic, socio-economic, and other divides. The harms inflicted upon the residents of these two communities are then not only material in nature, but distinctly harmful toward the socio-cultural fabric of the Los Angeles area. Yet as the two communities would soon discover, city, state, and power company officials—those responsible for the duty of protecting Angelenos—may carry an impermissibly high amount of responsibility for the blazes.
IV. THE PALISADES FIRE: WHERE NEGLIGENCE CLAIMS COULD FALL SHORT AND HOW TO STRENGTHEN THE CASE
The City of Los Angeles and the State of California were acutely aware of the severe fire risks posed by the region’s desert environment, yet both governments made a critical error in deciding to drain the Santa Ynez Reservoir that left firefighters with an incredibly limited water supply in their fight against the Palisades fire. The Santa Ynez Reservoir was the product of the Los Angeles Board of Recreation and Park Commissioners’s effort to protect the Palisades neighborhood in the event of a catastrophic wildfire. [28] However, when Santa Ynez’s water was needed, the reservoir’s supply had been completely drained. According to Los Angeles Department of Water and Power (LADWP), the Santa Ynez Reservoir needed to be emptied due to a breach in the reservoir’s floating cover that allowed contaminants to enter the water supply. [29] The reservoir sat empty for a year before the Palisades fire sparked, with no official reports of repair progress commencing. The Santa Ynez Reservoir’s year-long depletion with no visible progress on repairs can be attributed to the California Public Contract Code, which states that “all contracts for new construction estimated to cost in excess of twenty-five thousand dollars shall be left to the lowest responsible bidder after competitive bidding.” [30] Palisades residents were furious to find out that a potential lifeline like the Santa Ynez Reservoir in a crisis like this historic fire could be delayed by the state bureaucracy. At this point, the legal duty of the City of Los Angeles and the State of California, the breach of duty committed by these government actors as defendants in court, and the remediable harm are clear in a case between Palisades community member plaintiffs and government defendants. The City of Los Angeles and the State of California have a clear legal duty to adequately plan for and protect their citizens against the heightened possibility of a fire which they have acknowledged in the Palisades by constructing of the Santa Ynez Reservoir. The City of Los Angeles and the State of California have subsequently breached that duty due to the emptying of and unnecessarily prolonged delays in refilling the Santa Ynez Reservoir associated with the California Public Contract Code. Following this line of reasoning, the demonstrated and remediable harm suffered by the plaintiffs in a lawsuit against these government entities is clear: 6,800 buildings burned and 36.5 acres of the Santa Monica Mountains scorched as a consequence. [31] Just this March, the McNulty Law Firm and the Wood Law Firm filed suit against LADWP, claiming that the destruction of the Palisades Fire was the result of the “inescapable and unavoidable consequence” of poorly planned and inept water systems in and around the Palisades neighborhood. [32] These two lawsuits allege that the inadequacy of the water distribution system—like fire hydrants and pipes running dry due to a lack of water present in the Santa Ynez Reservoir—“was a substantial factor in causing plaintiffs to suffer the losses alleged.” [33] The McNulty suit, filed as Afshar et al. v. City of Los Angeles on March 5, 2025, claims negligence on the part of the City of Los Angeles for a defective and inadequate water distribution system and their prolonged delay in repair that contributed substantially toward the water shortage in the earliest hours of the Palisades fire. [34] However, notable speculation remains around whether the Santa Ynez Reservoir’s water even at full capacity and complete availability would have been able to tip the scales against the inferno. Experts like Stanford University hydrologist David Freyberg warned that while a Santa Ynez Reservoir at full capacity could have made a marginal difference, the creation of reservoirs like this one are mainly for use in fighting house fires—not wildfires of unprecedented size like this one. [35] If the Santa Ynez Reservoir, even at full capacity, could have potentially helped only marginally to fight the wildfire and had never been designed to do so in the first place, cases like Ashfar that rely on the drainage of the Santa Ynez as substantial cause for plaintiff’s injuries would fail to uphold their burden of proof and would thus likely be ruled unfavorably for the plaintiff.
On the other hand, counsel representing the plaintiffs could attempt to argue that the Santa Ynez Reservoir’s drainage meets California’s substantial cause test on the grounds that while the Reservoir’s depletion may not be the only cause of property and community loss in the Palisades resulting from the fire, a full and readily available water supply specifically designed to mitigate fire damage would have been a substantial aid in saving any amount of property and natural area. Indeed, this counsel would be wise to adopt the claims made in the lawsuit Smith, et al. v. City of Los Angeles filed on March 20th, 2025. [36] The suit claims it is an unavoidable truth that a filled Santa Ynez reservoir could have helped the condition of the Palisades neighborhood no matter how marginally. [37] Additionally, the suit alleges that active LADWP power lines publicly stated by the agency to have been de-energized years prior were in fact “active at the time of ignition” and a highly likely cause for the Palisades fire from the outset. [38] The Smith lawsuit brings forward a letter “purportedly written by Nicholas D. Fram,” a partner at Munger, Tolls, and Olsen LLC and LADWP counsel, alleging that LADWP surveillance footage captured blatant evidence both of energized lines and defects within those lines at the time of the Palisades fire’s ignition and in the late night hours of January 7th. [39] Shockingly, evidence brought by Smith also includes written and dated concession from LADWP that the lines in question at the ignition point of the Palisades fire were in fact live, contradicting LADWP’s repeated public statements that the lines had been de-energized for the past five years and therefore could not have been responsible for the disastrous fire. [40] Concrete evidence like this would significantly undermine the defense’s ability to dispute liability on the grounds that the Santa Ynez Reservoir had never been designed to mitigate wildfires. A negligence suit like Smith would have a heightened ability to assert the legal duty of the City of Los Angeles acting by the LADWP to adequately plan for and protect their citizens against the heightened possibility of fire and wildfire damage, the clear breach of duty by the LADWP’s failure to safely maintain their equipment, and irrefutable harm to property and human life resulting from the fire with evidence that clearly meets California’s substantial cause test (the defectiveness of the lines sparking the fire) establishing both proximate and “but for” causation. Prompted by legal action against the City of Los Angeles and increasing public outcry, Governor Gavin Newsom has announced an independent, state investigation into the decreased water availability and lack of water in the Santa Ynez Reservoir. [41] Furthermore, he has instructed the LADWP to produce a “comprehensive review” of the department’s efforts to ensure water availability for not just the Palisades neighborhood, but the entire City of Los Angeles as well. [42] This new evidence brought to light by Smith is yet another harrowing reminder of the extensive history of liability for wildfires of this scale being rightfully traced back to and placed on power companies. While in the Palisades Fire the City of Los Angeles and the LADWP have been brought into legal action as defendants, in the case of the Eaton Fire the city assumes a prosecutorial role.
V. THE EATON FIRE—HISTORICAL LIABILITY, GOVERNMENT ACCOUNTABILITY, AND EFFECTIVE NEGLIGENCE LITIGATION
California is a state long plagued by wildfires, and the blazes of the past have shown that damaged and malfunctioning equipment from power and utility companies is a leading cause of catastrophic fires. Pacific Gas & Electric, one of California’s largest utility companies, has been found to be responsible for $30 billion in damages resulting from wildfires sparked by faulty equipment and or improper maintenance. [43] In the case of the Eaton fire, Los Angeles County has begun the process of placing liability on Southern California Edison and Edison International for residential, commercial, educational, and public losses in Altadena. [44] Los Angeles County has mounted a clear defense strategy against both Southern California Edison and Edison International complete with photographic, eyewitness, and video reports proving that the fire started directly below Southern California Edison transmission lines within Eaton Canyon. [45] Here, Los Angeles County is clearly able to demonstrate the duty of care both Southern California Edison and Edison International had to uphold. This duty of care includes proper maintenance and monitoring of their transmission lines within Eaton Canyon and can show not only that the fire is related to an Edison defect through the aforementioned evidence constituting a breach of the defendants’ duty, but also that Southern California Edison admitted their error by sending communication of a “fault” in their transmission line to the California Public Utilities Commission (CPUC) around the exact time the Eaton fire was started. [46] The evidence stacks higher against Southern California Edison and Edison International with Los Angeles County’s presentation of evidence in the form of a letter sent by Southern California Edison on February 6th to the CPUC disclosing “potential arcing and damage on the grounding equipment for two out of the three idle conductors” along the MesaSylmar transmission line (the line responsible for igniting the Eaton Fire). [47] Los Angeles County can demonstrate clear harm from the grave consequences of the Eaton fire burning 14,000 acres, destroying 9,400 structures, and claiming the lives of 17 community members amongst other highly quantifiable harms. [48]
In terms of Southern California Edison and Edison International’s defense, it is entirely within their rights to, for example, try to contest or diminish their liability for the Eaton Fire in a negligence lawsuit on the basis of the “Act of God” defense, a negligence defense that accounts for the unforeseeable circumstances and inability to completely estimate the impacts of a natural disaster. The “Act of God” defense rests on three criteria: “foreseeability of the natural event, the frequency of its occurrence, and the defendant’s negligence and proximate cause.” [49] In a lawsuit against Southern California Edison and Edison international, the defendants could raise a valid contention rooting in the particularly hazardous wind conditions on January 7th. At the time of ignition, consistent winds speeds at 50 miles per hour and gusts regularly reaching 80 miles per hour were recorded, [50] well above Altadena’s year-round average wind speeds of a mere 8.3 miles per hour. [51] However, this is where the validity of the defendants’ “Act of God” defense would end. The foreseeability of these wind speeds is entirely possible, as they are the result of the annual Santa Ana winds. The Santa Anas are particularly intense gusts blowing westward from desert states like Utah and Arizona during the fall and winter when high-pressure air accumulated over the summer months is pushed toward the ocean. [52] References to the Santa Anas are ubiquitous in popular culture media and anemology records alike. [53] Consequently, this “Act of God” defense would fail on the first two criteria. Moreover, the extensive multimedia documentation serving as evidence pointing toward Southern California Edison and Edison International’s transmission line fault is highly valuable information that would likely pass the State of California’s substantial cause test to determine liability on the defendants, establishing a clear case for both proximate and “but for” cause by Southern California Edison and Edison International; if the two Edison entities had effectively and safely maintained the grounding equipment for the two malfunctioned or otherwise suboptimal idle conductors, there is a high likelihood that the Eaton Fire may not have occurred in the first place, much less caused the extent of harm that the blaze did.
In evaluating a potential contributory negligence defense, the Edison defendants would have to find viable and convincing evidence that the plaintiff, Los Angeles County, had acted in a manner that “falls below a certain standard necessary for the plaintiff’s protection.” [54] While a possible refutation may exist in alleged misconduct by the City of Los Angeles in its drainage of the Santa Ynez Reservoir and consequent water shortage during the dire need of the Palisades Fire, in the example of the Eaton Fire the same does not hold true. Defendants could try to claim that the dramatic delay in the emergency notification system warning residents of West Altadena to evacuate was an example of Los Angeles’s negligence to protect its citizens, therefore constituting contributory negligence. [55] Despite the fire breaking out just after 6:00pm the evening of January 7th, West Altadena residents were not notified to evacuate until roughly 3:30 am the morning of January 8th. [56] With all 17 deaths counted as a result of the Eaton fire being West Altadena residents, allegations that the Los Angeles County Fire and Sheriff’s Departments failed to adequately and promptly notify West Altadena residents of the impending danger appear to give the Edison defendants evidence for a successful contributory negligence claim against the plaintiff.57 However, as multiple Los Angeles County Fire officials attested, the night of January 7th was “pure chaos;” “hurricane-force winds” brought swaths of live embers across the entirety of Altadena. [58] With no way to obtain aerial footage or measurements of the fireline that night and firefighters spread thin throughout the burning Los Angeles County, it is entirely “possible that fire and sheriff’s officials may not have realized that swaths of West Altadena were engulfed by flames” prior to their warning. [59] There is no concrete evidence that in the Altadena area, any Los Angeles County operations were in any way putting residents at a heightened risk to wildfire; currently there is little reason to believe that the Los Angeles County Fire and Sheriff's Departments operated in any manner but in “unified command” with the Angeles National Forest and Pasadena Fire Departments, the Office of Emergency Management, and all other Los Angeles County organization to fight the blaze to the best of their unified ability. [60] Rather, the viability Southern California Edison and Edison International’s contributory negligence claim would rest on the findings of ongoing investigations into audiovisual records of the night of January 7th and early morning of January 8th like the investigation currently underway from the McChrystal Group. Only time will tell whether the McChrystal Group’s investigation can determine the root cause of evacuation delays, and whether any Los Angeles County officials had definite prior knowledge of the fire reaching West Altadena. The consequences of a contributory negligence claim would, in theory, be severe for Los Angeles County; even if a plaintiff was found to be only slightly contributory to the injury they suffered, they could be barred from receiving any damages whatsoever. [61]
Luckily, California is one of the majority states in the Union to instead adopt a “pure comparative negligence” standard. Los Angeles County can simultaneously be found to be partially responsible for the harms caused by the Eaton Fire due to their delayed evacuation of west Altadena and still recover damages from the Edison defendants. [62] The “pure comparative negligence” doctrine assigns blame for harms according to court-determined “percentage faults” that are later subtracted from total awards. [63] In the event the McChrystal Group’s findings, which Los Angeles County officials have agreed to make public upon their completion, determine any culpability from Los Angeles County, it is still highly likely that Los Angeles County will be awarded a high proportion of the crucial damages it needs to rebuild.
Indeed, this probability has fueled confidence within Altadena residents to file a host of negligence and class action lawsuits against Southern California Edison and Edison International, following the outline set by Los Angeles County to build tactful cases. A plaintiff seeking to hold a defendant criminally liable must show that these harms are tangible and that there would be a clear remedy to these harms: damages awarded. For Los Angeles County, damages would be a clear, attainable remedy that goes toward rebuilding the affected areas of Altadena, Pasadena, and Sierra Madre burned by the Eaton fire. However, damages awarded in this litigation and the claims filed by residents themselves would represent far more than mere payment for the costs of the fire. Along with the homes, schools, restaurants, art galleries, banks, parks, and gardens lost to the Palisades and Eaton fires, community legacies went up in flames; the very sense of place itself was burned along with the physical sense of the word. Instead, damages as a remedy in cases around the Eaton fire would also signify a critical acknowledgement and effort to heal the acute emotional trauma sustained by these communities in the aftermath of the blazes.
Endnotes
[1] Natalia Osuna, “Here Is a Timeline of the Eaton and Palisades Fires in LA County,” NBC Los Angeles, January 25, 2025, https://www.nbclosangeles.com/news/california-wildfires/timeline-eaton-palisades-fires-lacounty/3614940/.
[2] “12 Hours of Fire That Decimated Altadena: ‘I’m Going to Lose Half of My Town,’” Los Angeles Times, January 17, 2025, https://www.latimes.com/california/story/2025-01-17/chaotic-first-hours-eaton-fire-timelinemaps#:~:text=The%20Eaton%20fire%2C%20captured%20at,about%2020%20minutes%20after%20ignition.&text= Firefighters%20were%20protecting%20homes%20at,from%20the%20flames%2C%20behind%20firefighters.
[3] Jeremia Kimelman, “The LA County Fires Devastated Homes in the Wildland Urban Interface. Here’s What That Is ,” CalMatters, January 28, 2025, https://calmatters.org/environment/wildfires/2025/01/la-county-fires-wildlandurban-interface/#:~:text=The%20most%20destructive%20fires%20in,28%20people%20as%20of%20Jan.[4 “The Palisades and Eaton Fires in Los Angeles Have Destroyed 14% of Homes within the Fire Perimeters,” Redfin Corporation, January 17, 2025, https://investors.redfin.com/news-events/press-releases/detail/1252/the-palisadesand-eaton-fires-in-los-angeles-havedestroyed#:~:text=SEATTLE%2D%2D(BUSINESS%20WIRE)%2D%2D,905%20(14%25)%20were%20damaged.
[5] TodayShow, “What We Know about the Victims Killed in the California Wildfires,” TODAY.com, January 13, 2025, https://www.today.com/news/news/california-wildfires-victims-rcna187222.
[6] William Brangham, Sam Lane, and Mike Fritz, “California Faces Insurance Crisis as Homeowners Lose Coverage amid Extreme Weather,” PBS, February 10, 2025, https://www.pbs.org/newshour/show/california-faces-insurancecrisis-as-homeowners-lose-coverage-amid-extremeweather#:~:text=Before%20thousands%20lost%20their%20homes,extreme%20weather%2C%20was%20too%20gr eat
[7] William Brangham, Sam Lane, and Mike Fritz, “California Faces Insurance Crisis as Homeowners Lose Coverage amid Extreme Weather”.
[8] Dan Burrows, “The 15 Most Expensive Housing Markets in the US: Real Estate with the Highest Average Home Prices,” Kiplinger.com, October 20, 2021, https://www.kiplinger.com/real-estate/603612/15-us-cities-with-thehighest-average-home-prices
[9] Ronald V. Miller, “La Wildfires Lawsuit,” Lawsuit Information Center, March 31, 2025, https://www.lawsuitinformation-center.com/la-wildfireslawsuit.html#:~:text=The%202025%20Los%20Angeles%20wildfires,and%20inadequate%20fire%20prevention%2 0measures
[10] “Negligence,” Legal Information Institute, accessed April 10, 2025, https://www.law.cornell.edu/wex/negligence.
[11] Sasha Bojat, “What Is Proximate Cause: A Personal Injury Law Guide,” Bojat Law Group, December 19, 2024, https://www.bojatlaw.com/blog/what-is-proximate-cause-in-personal-injuryclaims/#:~:text=In%20California%20legal%20theory%20and,omission)%20and%20the%20resulting%20harm.
[12] Sasha Bojat, “What Is Proximate Cause: A Personal Injury Law Guide”.
[13] Sasha Bojat, “What Is Proximate Cause: A Personal Injury Law Guide”.
[14] Michael Edlen, “Pivotal Moments in Pacific Palisades History: The Year 1929 " Michael Edlen & the Edlen Team,” Michael Edlen & The Edlen Team, March 14, 2025, https://edlenteam.com/pivotal-moments-in-pacificpalisades-history-the-year-1929/.
[15] “Pacific Palisades,” referenceworks, accessed April 11, 2025, https://referenceworks.brill.com/display/entries/EJHC/COM-0611.xml?language=en.
[16] “Pacific Palisades”.
[17] Michael Edlen, “Pivotal Moments in Pacific Palisades History: The Year 1929 " Michael Edlen & the Edlen Team,” Michael Edlen & The Edlen Team, March 14, 2025, https://edlenteam.com/pivotal-moments-in-pacificpalisades-history-the-year-1929/.
[18] Michael Edlen, “Pivotal Moments in Pacific Palisades History: The Year 1929”.
[19] Spencer Elliott, “These Are the Most Expensive Neighborhoods on L.A.’s Westside,” Forbes, October 12, 2022, https://www.forbes.com/sites/forbes-global-properties/2022/08/14/these-are-the-most-expensive-neighborhoods-onlas-westside/.
[20] Business Standard, “Firefighters’ Nightmare: How Palisades Fire Became the Worst in LA History,” Business Standard, January 10, 2025, https://www.business-standard.com/world-news/palisades-fire-la-history-worstfirefighters-challenges-125011000573_1.html.
[21] “A Short History of Altadena,” Altadena Heritage, accessed April 11, 2025, https://altadenaheritage.org/a-shorthistory-of-altadena/.
[22] “A Short History of Altadena”.
[23] “A Short History of Altadena”.
[24] “A Short History of Altadena”.
[25] Interview with Mary McGilvary, President of the Altadena Community Garden.
[26] For Black Families in Altadena, History and Community Burned alongside Homes,” The Guardian, January 18, 2025, https://www.theguardian.com/us-news/2025/jan/18/altadena-fire-blackfamilies#:~:text=Altadena%2C%20a%20quiet%2C%20tight%2D,homes%20elsewhere%20in%20the%20state.
[27] “For Black Families in Altadena, History and Community Burned alongside Homes'“.
[28] “When L.A. Fires Broke out, the 117-Million Gallon Santa Ynez Reservoir near Pacific Palisades Was Empty. Here’s What We Know.,” CBS News, accessed April 11, 2025, https://www.cbsnews.com/news/la-fires-santa-ynezreservoir-pacific-palisades-california/.
[29] “State to Probe Why Pacific Palisades Reservoir Was Offline, Empty When Firestorm Exploded,” Los Angeles Times, January 10, 2025, https://www.latimes.com/california/story/2025-01-10/as-flames-raged-in-palisades-a-keyreservoir-nearby-was-offline.
[30] California Code, public contract code - PCC § 20815.1, accessed April 11, 2025, https://codes.findlaw.com/ca/public-contract-code/pcc-sect-20815-1/.
[31] “Mapping the Damage from the Eaton and Palisades Fires,” Los Angeles Times, January 16, 2025, https://www.latimes.com/california/story/2025-01-16/mapping-los-angeles-damage-from-the-eaton-and-palisadesfires-altadena-pasadena.
[32] “New Lawsuit Targets Dry Hydrants, Empty Reservoir in Palisades Fire,” Homepage, accessed April 11, 2025, https://www.dailyjournal.com/articles/384150-new-lawsuit-targets-dry-hydrants-empty-reservoir-in-palisades-fire.
[33] “New Lawsuit Targets Dry Hydrants, Empty Reservoir in Palisades Fire”.
[34] “New Lawsuit Targets Dry Hydrants, Empty Reservoir in Palisades Fire”.
[35] When L.A. Fires Broke out, the 117-Million Gallon Santa Ynez Reservoir near Pacific Palisades Was Empty. Here’s What We Know.,” CBS News, accessed April 11, 2025, https://www.cbsnews.com/news/la-fires-santa-ynezreservoir-pacific-palisades-california/.
[36] “Lawsuits Claim LADWP Power Lines Caused Palisades Fire, Claim Cover-Up,” Homepage, accessed April 11, 2025, https://www.dailyjournal.com/articles/384513-lawsuits-claim-ladwp-power-lines-caused-palisades-fire-claimcover-up
[37] “Lawsuits Claim LADWP Power Lines Caused Palisades Fire, Claim Cover-Up”.
[38] “Lawsuits Claim LADWP Power Lines Caused Palisades Fire, Claim Cover-Up”.
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[40] “Lawsuits Claim LADWP Power Lines Caused Palisades Fire, Claim Cover-Up”.
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