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By Chuan Qin and Adam Mills Masarek1 Los Angeles Superior Court has long served as one of the nation’s busiest and most influential trial courts. Over the last several years, however, one category...
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By Chuan Qin and Adam Mills Masarek1
Los Angeles Superior Court has long served as one of the nation’s busiest and most influential trial courts. Over the last several years, however, one category of litigation has undergone a dramatic transformation: California Rule of Court 3.400 ("CRC 3.4") complex civil litigation. In Los Angeles Superior Court, CRC 3.4 designations have become increasingly common across employment, institutional tort, utility, and public entity litigation.
Data from Lex Machina®, the LexisNexis® Legal Analytics® platform, reveals two distinct waves of growth in CRC 3.4 case filings in Los Angeles Superior Court. The first wave arrived in 2022, driven largely by coordinated tort litigation against Catholic Church entities and local government defendants. A second and ongoing wave began in 2024, fueled primarily by employment litigation and a growing number of “other civil” disputes involving utilities and public entities.
Cases Filed by Year That Received a CRC 3.4 Designation, Los Angeles County Superior Court (January 1, 2016-May 29, 2026)
The result is a fundamental shift in the composition of the court’s civil docket. Once associated primarily with large commercial disputes and coordinated mass torts, complex litigation is now arising from a much broader range of case types.
Los Angeles experienced a pronounced surge in CRC 3.4-designated filings in 2022, with complex case filings rising well above historical levels. The increase was driven overwhelmingly by tort actions outside the motor vehicle, product liability, and medical malpractice categories. In particular, lawsuits involving Catholic Church entities and local government organizations accounted for a substantial share of the growth, with filings in those matters increasing more than tenfold from 2021 to 2022. Plaintiffs filed 3,734 such cases in Los Angeles in 2022, the most in a single year since at least 2016.
Cases Filed by Year That Received a CRC 3.4 Designation, Los Angeles County Superior Court, Tort Cases Other Than Motor Vehicle, Product Liability, or Medical Malpractice (January 1, 2016-May 29, 2026)
This timing aligns with the statewide wave of childhood sexual abuse litigation that followed Assembly Bill 218, which expanded the statute of limitations and created a temporary revival window for previously time-barred claims. See Cal Code Civ Proc § 340.16, K.M. v. Grossmont Union High School Dist., 84 Cal. App. 5th 717 (2022). As a result, plaintiffs filed large numbers of actions against dioceses, archdioceses, religious organizations, schools, and related institutional defendants throughout California. Many of these matters were designated as complex under CRC 3.4. Those cases typically involve varying numbers of plaintiffs, extensive historical discovery, and complicated questions of institutional liability.
After declining in 2023, complex filings resumed their upward trend in 2024, with a year-over-year increase of about 274% (2,667 vs. 973). The rise in CRC 3.4 filings since 2024 has been driven in large part by employment litigation. A significant portion of these matters involve claims that require extensive workforce-wide discovery and procedural management, unlike traditional single-plaintiff employment disputes that are simpler to resolve.
Employment Cases Filed by Year That Received a CRC 3.4 Designation, Los Angeles County Superior Court, (January 1, 2016-May 29, 2026)
Unlike the 2022 surge, the increase in employment litigation does not appear to be driven by a handful of repeat defendants or coordinated campaigns. No single employer defended against more than seven new CRC 3.4 employment lawsuits in Los Angeles between January 2025 and April 2026, suggesting that the increase reflects a broader shift in employment litigation rather than concentrated activity against a small number of defendants.
The data suggests that several broader developments in Los Angeles employment litigation are contributing to this trend:
As employment litigation continues evolving in both scale and sophistication, more cases appear to be meeting the threshold for complex designation.
The data also highlights another important trend: a growing number of “other civil” complex cases involving utilities and local government defendants, particularly following recent major wildfires in Southern California. Between January 1, 2025, and May 21, 2026, more than 1,800 lawsuits were filed against Southern California Edison Company and Edison International alleging that their electrical infrastructure caused or contributed to damages arising from major Los Angeles County wildfires, most notably the Eaton and Palisades fires in January 2025.
Many of these cases received a CRC 3.4 designation because they involve numerous parties, substantial documentary evidence, extensive expert discovery, and overlapping questions of fact and law. The Eaton Fire litigation also presents significant coordination challenges because many plaintiffs seek recovery based on a common set of underlying events and allegations. These features make the cases well suited for management through California's complex litigation program, which provides a framework for coordinating hundreds or thousands of related claims and resolving common issues more efficiently.
Historically, CRC 3.4 designations were commonly associated with commercial litigation, securities disputes, and coordinated mass tort proceedings. Recent filing patterns suggest that the practical definition of a "complex" case is broadening as courts confront increasingly sophisticated employment, institutional liability, utility, and public entity disputes.
This evolution carries meaningful implications for litigants and practitioners:
The trends also reinforce the importance of tracking procedural classifications alongside substantive case types. The CRC 3.4 designation often signals higher litigation stakes, broader discovery, and longer case timelines.
Complex civil litigation in Los Angeles Superior Court became increasingly common from 2019 through 2025, rising from 1.4% of all non-collections lawsuits in 2019 to 6.5% in 2025. Regardless, the CRC 3.4 designation is no longer confined to isolated waves of commercial disputes, but rather broader structural trends tied to evolving employment practices and the increasing litigation consequences of major wildfire events.
The 2022 spike reflected the extraordinary impact of Catholic Church and public entity tort litigation. The current increase, however, appears broader and potentially more durable, reflecting developments in both employment litigation and large-scale disaster-related litigation. If these trends continue, Los Angeles Superior Court may offer an early indication of how complex civil litigation is evolving throughout California.
For litigators, insurers, corporate counsel, and public entities alike, understanding these shifts is essential to anticipating litigation risk, allocating resources, and developing effective case strategy.
As California Rule of Court 3.400 (CRC 3.4) filings continue to evolve, staying ahead of emerging litigation trends is critical for developing effective case strategies and managing risk. Lex Machina® delivers data-driven insights into complex litigation, helping legal professionals analyze filing trends, identify patterns across courts and case types, evaluate judges and parties, and make more informed strategic decisions.
Whether you're tracking employment litigation, institutional liability, wildfire-related claims, or other complex civil matters, Lex Machina provides the legal analytics needed to better understand the litigation landscape and prepare for what's ahead.
Learn how Lex Machina can help you analyze complex litigation trends and make more informed litigation decisions.
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