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Utilities
10 min read
Areas of Expertise :
Air Quality, Toxicology, Epidemiology, Economic Damages
Published Date:
Last Modified Date:
Jurisdiction:
California State
Court:
The Dixie Fire began in Northern California on July 13, 2021, and burned approximately 963,309 acres across Butte, Plumas, Shasta, Lassen, and Tehama Counties. CAL FIRE determined that the fire started after a tree contacted electrical distribution lines owned and operated by Pacific Gas and Electric Company (PG&E). The wildfire remained active for more than three months, destroying homes and other property while sending smoke across a much wider area. Litigation that followed involved thousands of plaintiffs seeking recovery for property damage, personal injuries, wrongful death, economic losses, medical monitoring, and other alleged harm.
A separate action, Lara Wheeler and Julie Peterson v. PG&E Corporation et al., Case No. CGC-23-607657, addressed alleged exposure to Dixie Fire and Fly Fire smoke. Filed on July 13, 2023, the complaint asserted negligence and medical-monitoring claims on behalf of a proposed class that included people who owned or rented property, or otherwise resided, in specified areas of Northern California and Northern Nevada. The case went through several amended complaints and challenges to the pleadings before the plaintiffs sought class certification in December 2025. The court denied that motion on July 20, 2026, while other litigation arising from the Dixie Fire continued separately.
The Dixie Fire started above the Cresta Dam in the Feather River Canyon in Northern California. It spread across portions of five counties as crews worked to contain the expanding wildfire. Residents were evacuated from affected communities, and the fire damaged or destroyed homes, businesses, forests, public facilities, and other property. Smoke traveled beyond the burn area as the fire continued through the summer and fall.
CAL FIRE's incident record lists full containment on October 25, 2021, after approximately 104 days of fire activity. The agency reported a final burn area of about 963,309 acres. The fire affected Butte, Plumas, Shasta, Lassen, and Tehama Counties and became one of California's largest recorded wildfires. The prolonged smoke conditions later appeared in allegations seeking medical monitoring for people outside the immediate areas of property destruction.
CAL FIRE announced that its investigation determined the fire began when a tree contacted PG&E electrical distribution lines. Investigators examined the condition of the tree, vegetation inspection practices, and events surrounding the electrical fault and outage before the fire spread. Civil plaintiffs later brought claims involving PG&E's vegetation management, utility operations, and response to the initial electrical event. PG&E disputed a number of allegations concerning its conduct and maintained that its personnel acted reasonably based on the information available at the time.
A California coordination motion judge granted coordination of multiple Dixie Fire lawsuits for pretrial proceedings on February 7, 2022. The coordinated cases became known as Dixie Fire Cases, JCCP No. 5208. The litigation included allegations involving property damage, personal injury, wrongful death, economic loss, negligence, nuisance, inverse condemnation, and other wildfire damages. Claims involving the fire's origin, PG&E's actions, and damages were addressed through the coordinated proceeding.
Lara Wheeler and Julie Peterson filed a separate putative class action against PG&E Corporation, Pacific Gas and Electric Company, and unnamed defendants in San Francisco Superior Court. The complaint asserted two causes of action: negligence and medical monitoring. The proposed class included people who owned or rented property, or otherwise resided, in specified areas of Northern California and Northern Nevada during the period addressed by the complaint. Plaintiffs alleged that smoke from the Dixie Fire and Fly Fire exposed people to substances that could create increased health risks requiring future medical surveillance.
PG&E Corporation and Pacific Gas and Electric Company filed a demurrer to the putative class complaint on August 23, 2024. The challenge addressed whether the allegations, as pleaded, were sufficient to allow the action to continue in its existing form. The litigation remained focused on the negligence and medical-monitoring theories asserted by the plaintiffs. Further amendments followed as the parties continued to litigate the pleadings.
On January 13, 2025, the court ordered that the plaintiffs had 30 days to amend their complaint or the case would be abated. The order gave the plaintiffs another opportunity to revise their allegations rather than ending the action at that stage. Plaintiffs filed an amended complaint within that period on February 12, 2025. PG&E then filed its answer on March 18, 2025.
PG&E filed an amended answer on April 18, 2025, after responding to the plaintiffs' revised complaint the previous month. The parties then disputed portions of PG&E's pleading through a demurrer and motion to strike filed by the plaintiffs. These procedural disputes addressed the defenses that would remain in the case as litigation moved forward. The court resolved those challenges later in 2025.
On October 3, 2025, the court overruled the plaintiffs' demurrer to portions of PG&E's answer and denied their motion to strike. The challenged defenses therefore remained part of the case. The ruling left the parties to continue litigating the medical-monitoring action under the existing pleadings. Attention then moved to whether the plaintiffs could pursue the claims through a certified class.
Plaintiffs filed a motion for class certification on December 12, 2025. They sought permission to pursue the medical-monitoring claims on behalf of the proposed group rather than through claims brought only by the named plaintiffs. Class certification required the court to determine whether the case met the legal requirements for class treatment. The motion remained pending as the litigation continued into 2026.
Plaintiffs filed their fifth amended complaint on January 28, 2026. The filing continued the medical-monitoring litigation after earlier revisions to the pleadings and challenges from both sides. By then, the case had gone through several rounds of amendments as the parties defined the allegations and defenses that remained before the court. The pending motion for class certification continued alongside the revised complaint.
The court denied the plaintiffs' motion for class certification on July 20, 2026. As a result, the proposed medical-monitoring claims were not permitted to proceed as a certified class under that motion. The ruling addressed class treatment rather than resolving every individual claim based on alleged smoke exposure. The separate body of Dixie Fire litigation against PG&E also continued outside the class-certification proceeding.
As of July 15, 2026, PG&E reported approximately 190 complaints brought on behalf of at least 9,062 individual plaintiffs in connection with the 2021 Dixie Fire. The reported demands included wrongful death, property damage, economic loss, medical monitoring, punitive and exemplary damages, attorneys' fees, and other claimed damages. PG&E stated that a substantial majority of those claims had been resolved. At that time, no broader Dixie Fire trial was scheduled.
Superior Court of California, County of San Francisco
Case Name:
Lara Wheeler and Julie Peterson v. PG&E Corporation
Atmospheric Sciences
Atmospheric dispersion modeling
Smoke Inhalation
Environmental Toxicology
Occupational And Environmental Health
Environmental hazards
Environmental Sampling
Environmental Medicine
Forest Fire
The Dixie Fire began in Northern California on July 13, 2021, and burned approximately 963,309 acres across Butte, Plumas, Shasta, Lassen, and Tehama Counties. CAL FIRE determined that the fire started after a tree contacted electrical distribution lines owned and operated by Pacific Gas and Electric Company (PG&E). The wildfire remained active for more than three months, destroying homes and other property while sending smoke across a much wider area. Litigation that followed involved thousands of plaintiffs seeking recovery for property damage, personal injuries, wrongful death, economic losses, medical monitoring, and other alleged harm.
A separate action, Lara Wheeler and Julie Peterson v. PG&E Corporation et al., Case No. CGC-23-607657, addressed alleged exposure to Dixie Fire and Fly Fire smoke. Filed on July 13, 2023, the complaint asserted negligence and medical-monitoring claims on behalf of a proposed class that included people who owned or rented property, or otherwise resided, in specified areas of Northern California and Northern Nevada. The case went through several amended complaints and challenges to the pleadings before the plaintiffs sought class certification in December 2025. The court denied that motion on July 20, 2026, while other litigation arising from the Dixie Fire continued separately.
The Dixie Fire started above the Cresta Dam in the Feather River Canyon in Northern California. It spread across portions of five counties as crews worked to contain the expanding wildfire. Residents were evacuated from affected communities, and the fire damaged or destroyed homes, businesses, forests, public facilities, and other property. Smoke traveled beyond the burn area as the fire continued through the summer and fall.
CAL FIRE's incident record lists full containment on October 25, 2021, after approximately 104 days of fire activity. The agency reported a final burn area of about 963,309 acres. The fire affected Butte, Plumas, Shasta, Lassen, and Tehama Counties and became one of California's largest recorded wildfires. The prolonged smoke conditions later appeared in allegations seeking medical monitoring for people outside the immediate areas of property destruction.
CAL FIRE announced that its investigation determined the fire began when a tree contacted PG&E electrical distribution lines. Investigators examined the condition of the tree, vegetation inspection practices, and events surrounding the electrical fault and outage before the fire spread. Civil plaintiffs later brought claims involving PG&E's vegetation management, utility operations, and response to the initial electrical event. PG&E disputed a number of allegations concerning its conduct and maintained that its personnel acted reasonably based on the information available at the time.
A California coordination motion judge granted coordination of multiple Dixie Fire lawsuits for pretrial proceedings on February 7, 2022. The coordinated cases became known as Dixie Fire Cases, JCCP No. 5208. The litigation included allegations involving property damage, personal injury, wrongful death, economic loss, negligence, nuisance, inverse condemnation, and other wildfire damages. Claims involving the fire's origin, PG&E's actions, and damages were addressed through the coordinated proceeding.
Lara Wheeler and Julie Peterson filed a separate putative class action against PG&E Corporation, Pacific Gas and Electric Company, and unnamed defendants in San Francisco Superior Court. The complaint asserted two causes of action: negligence and medical monitoring. The proposed class included people who owned or rented property, or otherwise resided, in specified areas of Northern California and Northern Nevada during the period addressed by the complaint. Plaintiffs alleged that smoke from the Dixie Fire and Fly Fire exposed people to substances that could create increased health risks requiring future medical surveillance.
PG&E Corporation and Pacific Gas and Electric Company filed a demurrer to the putative class complaint on August 23, 2024. The challenge addressed whether the allegations, as pleaded, were sufficient to allow the action to continue in its existing form. The litigation remained focused on the negligence and medical-monitoring theories asserted by the plaintiffs. Further amendments followed as the parties continued to litigate the pleadings.
On January 13, 2025, the court ordered that the plaintiffs had 30 days to amend their complaint or the case would be abated. The order gave the plaintiffs another opportunity to revise their allegations rather than ending the action at that stage. Plaintiffs filed an amended complaint within that period on February 12, 2025. PG&E then filed its answer on March 18, 2025.
PG&E filed an amended answer on April 18, 2025, after responding to the plaintiffs' revised complaint the previous month. The parties then disputed portions of PG&E's pleading through a demurrer and motion to strike filed by the plaintiffs. These procedural disputes addressed the defenses that would remain in the case as litigation moved forward. The court resolved those challenges later in 2025.
On October 3, 2025, the court overruled the plaintiffs' demurrer to portions of PG&E's answer and denied their motion to strike. The challenged defenses therefore remained part of the case. The ruling left the parties to continue litigating the medical-monitoring action under the existing pleadings. Attention then moved to whether the plaintiffs could pursue the claims through a certified class.
Plaintiffs filed a motion for class certification on December 12, 2025. They sought permission to pursue the medical-monitoring claims on behalf of the proposed group rather than through claims brought only by the named plaintiffs. Class certification required the court to determine whether the case met the legal requirements for class treatment. The motion remained pending as the litigation continued into 2026.
Plaintiffs filed their fifth amended complaint on January 28, 2026. The filing continued the medical-monitoring litigation after earlier revisions to the pleadings and challenges from both sides. By then, the case had gone through several rounds of amendments as the parties defined the allegations and defenses that remained before the court. The pending motion for class certification continued alongside the revised complaint.
The court denied the plaintiffs' motion for class certification on July 20, 2026. As a result, the proposed medical-monitoring claims were not permitted to proceed as a certified class under that motion. The ruling addressed class treatment rather than resolving every individual claim based on alleged smoke exposure. The separate body of Dixie Fire litigation against PG&E also continued outside the class-certification proceeding.
As of July 15, 2026, PG&E reported approximately 190 complaints brought on behalf of at least 9,062 individual plaintiffs in connection with the 2021 Dixie Fire. The reported demands included wrongful death, property damage, economic loss, medical monitoring, punitive and exemplary damages, attorneys' fees, and other claimed damages. PG&E stated that a substantial majority of those claims had been resolved. At that time, no broader Dixie Fire trial was scheduled.
Air quality and atmospheric science experts can examine particulate matter measurements, Air Quality Index records, weather conditions, wind patterns, smoke dispersion, and data collected by monitoring stations. Their analysis may trace how smoke moved across communities and how pollutant levels changed over time. They can also compare conditions across different locations to evaluate the extent and duration of reported air-quality changes.
Toxicologists can assess substances associated with wildfire smoke, including their concentration and possible routes of human exposure. Their work may address the relationship between an estimated exposure and an alleged health risk. In a medical-monitoring dispute, toxicology analysis can also examine whether the claimed exposure is consistent with the type of future health surveillance being requested.
Experts in epidemiology and environmental health can examine research concerning wildfire smoke, particulate matter, respiratory conditions, cardiovascular effects, and population health data. They may compare health outcomes among groups with different levels of exposure or evaluate whether reported effects are consistent with existing scientific research. Their work can also address differences in location, health history, exposure duration, and other factors within a proposed group.
Economic damages experts can examine claimed lost earnings, business interruption, property-related losses, healthcare expenses, and projected medical-monitoring costs. Their analysis may involve financial statements, employment records, business data, and assumptions used to calculate past or future losses. The approach depends on the type of damages claimed and whether the analysis concerns an individual, a business, or a proposed group.
The medical-monitoring case was filed as Lara Wheeler and Julie Peterson v. PG&E Corporation et al., Case No. CGC-23-607657, in San Francisco Superior Court. It was separate from the many individual and coordinated lawsuits seeking recovery for property damage, bodily injury, wrongful death, economic loss, and other wildfire damages. The Wheeler action focused on alleged smoke exposure and a request for future medical surveillance.
The July 2023 complaint identified negligence and medical monitoring as its two causes of action. Plaintiffs alleged that exposure to wildfire smoke created an increased risk of health problems and sought a program for future surveillance. The requested relief differed from a claim limited to payment for an existing diagnosed condition or damaged property.
The original proposed class was not confined to California. It included people who owned or rented property, or otherwise resided, in specified areas of Northern California and Northern Nevada. Named plaintiff Julie Peterson was identified in the complaint as a resident of Washoe County, Nevada.
Plaintiffs identified particulate matter, carbon monoxide, carbon dioxide, nitrogen oxides, volatile organic compounds, polycyclic aromatic hydrocarbons, and other substances associated with wildfire smoke. They alleged that people in the proposed class experienced exposure as smoke from the Dixie Fire and Fly Fire moved through affected areas. The medical-monitoring request was based on the alleged health risks tied to that exposure.
The court denied class certification in the medical-monitoring action on July 20, 2026. That decision did not dispose of every lawsuit or individual claim arising from the Dixie Fire. PG&E continued to report a broader group of pending and resolved wildfire cases, with a substantial majority of claims reported as resolved by July 2026.
The Dixie Fire began on July 13, 2021, after a tree contacted PG&E electrical distribution lines and burned approximately 963,309 acres before CAL FIRE listed it as fully contained on October 25, 2021. Thousands of plaintiffs later pursued claims arising from the wildfire. In a separate action filed in July 2023, Lara Wheeler and Julie Peterson sought medical monitoring for a proposed group of people in Northern California and Northern Nevada who allegedly experienced wildfire smoke exposure. The case went through repeated amendments and pleading disputes, followed by a class-certification motion filed in December 2025 and a fifth amended complaint in January 2026. The court denied class certification on July 20, 2026, while other Dixie Fire litigation continued separately and many of the broader claims had already reached resolution.
What was the name of the Dixie Fire medical monitoring case?
The separate medical-monitoring action was Lara Wheeler and Julie Peterson v. PG&E Corporation et al., Case No. CGC-23-607657, filed in San Francisco Superior Court on July 13, 2023. The complaint asserted negligence and medical-monitoring claims against PG&E Corporation, Pacific Gas and Electric Company, and unnamed defendants.
What pollutants did the Dixie Fire complaint identify?
The complaint identified particulate matter, carbon monoxide, carbon dioxide, nitrogen oxides, volatile organic compounds, polycyclic aromatic hydrocarbons, and other substances associated with wildfire smoke. Plaintiffs alleged that exposure to those substances increased the risk of future health problems.
Who was included in the proposed Dixie Fire medical monitoring class?
The original proposed class included people who owned or rented property, or otherwise resided, in specified areas of Northern California and Northern Nevada. The complaint sought medical monitoring based on alleged exposure to smoke from the Dixie Fire and Fly Fire.
What happened to the motion for Dixie Fire class certification?
Plaintiffs filed their motion for class certification on December 12, 2025. The court denied the motion on July 20, 2026, so the proposed medical-monitoring claims did not receive certified-class status under that request.
Did the class-certification denial end the other Dixie Fire cases against PG&E?
No. The July 20, 2026 decision dealt with the proposed medical-monitoring class. PG&E reported approximately 190 complaints involving at least 9,062 individual plaintiffs as of July 15, 2026 and stated that a substantial majority of the broader claims had been resolved.
Air quality and atmospheric science experts can examine particulate matter measurements, Air Quality Index records, weather conditions, wind patterns, smoke dispersion, and data collected by monitoring stations. Their analysis may trace how smoke moved across communities and how pollutant levels changed over time. They can also compare conditions across different locations to evaluate the extent and duration of reported air-quality changes.
Toxicologists can assess substances associated with wildfire smoke, including their concentration and possible routes of human exposure. Their work may address the relationship between an estimated exposure and an alleged health risk. In a medical-monitoring dispute, toxicology analysis can also examine whether the claimed exposure is consistent with the type of future health surveillance being requested.
Experts in epidemiology and environmental health can examine research concerning wildfire smoke, particulate matter, respiratory conditions, cardiovascular effects, and population health data. They may compare health outcomes among groups with different levels of exposure or evaluate whether reported effects are consistent with existing scientific research. Their work can also address differences in location, health history, exposure duration, and other factors within a proposed group.
Economic damages experts can examine claimed lost earnings, business interruption, property-related losses, healthcare expenses, and projected medical-monitoring costs. Their analysis may involve financial statements, employment records, business data, and assumptions used to calculate past or future losses. The approach depends on the type of damages claimed and whether the analysis concerns an individual, a business, or a proposed group.
The medical-monitoring case was filed as Lara Wheeler and Julie Peterson v. PG&E Corporation et al., Case No. CGC-23-607657, in San Francisco Superior Court. It was separate from the many individual and coordinated lawsuits seeking recovery for property damage, bodily injury, wrongful death, economic loss, and other wildfire damages. The Wheeler action focused on alleged smoke exposure and a request for future medical surveillance.
The July 2023 complaint identified negligence and medical monitoring as its two causes of action. Plaintiffs alleged that exposure to wildfire smoke created an increased risk of health problems and sought a program for future surveillance. The requested relief differed from a claim limited to payment for an existing diagnosed condition or damaged property.
The original proposed class was not confined to California. It included people who owned or rented property, or otherwise resided, in specified areas of Northern California and Northern Nevada. Named plaintiff Julie Peterson was identified in the complaint as a resident of Washoe County, Nevada.
Plaintiffs identified particulate matter, carbon monoxide, carbon dioxide, nitrogen oxides, volatile organic compounds, polycyclic aromatic hydrocarbons, and other substances associated with wildfire smoke. They alleged that people in the proposed class experienced exposure as smoke from the Dixie Fire and Fly Fire moved through affected areas. The medical-monitoring request was based on the alleged health risks tied to that exposure.
The court denied class certification in the medical-monitoring action on July 20, 2026. That decision did not dispose of every lawsuit or individual claim arising from the Dixie Fire. PG&E continued to report a broader group of pending and resolved wildfire cases, with a substantial majority of claims reported as resolved by July 2026.
The Dixie Fire began on July 13, 2021, after a tree contacted PG&E electrical distribution lines and burned approximately 963,309 acres before CAL FIRE listed it as fully contained on October 25, 2021. Thousands of plaintiffs later pursued claims arising from the wildfire. In a separate action filed in July 2023, Lara Wheeler and Julie Peterson sought medical monitoring for a proposed group of people in Northern California and Northern Nevada who allegedly experienced wildfire smoke exposure. The case went through repeated amendments and pleading disputes, followed by a class-certification motion filed in December 2025 and a fifth amended complaint in January 2026. The court denied class certification on July 20, 2026, while other Dixie Fire litigation continued separately and many of the broader claims had already reached resolution.
What was the name of the Dixie Fire medical monitoring case?
The separate medical-monitoring action was Lara Wheeler and Julie Peterson v. PG&E Corporation et al., Case No. CGC-23-607657, filed in San Francisco Superior Court on July 13, 2023. The complaint asserted negligence and medical-monitoring claims against PG&E Corporation, Pacific Gas and Electric Company, and unnamed defendants.
What pollutants did the Dixie Fire complaint identify?
The complaint identified particulate matter, carbon monoxide, carbon dioxide, nitrogen oxides, volatile organic compounds, polycyclic aromatic hydrocarbons, and other substances associated with wildfire smoke. Plaintiffs alleged that exposure to those substances increased the risk of future health problems.
Who was included in the proposed Dixie Fire medical monitoring class?
The original proposed class included people who owned or rented property, or otherwise resided, in specified areas of Northern California and Northern Nevada. The complaint sought medical monitoring based on alleged exposure to smoke from the Dixie Fire and Fly Fire.
What happened to the motion for Dixie Fire class certification?
Plaintiffs filed their motion for class certification on December 12, 2025. The court denied the motion on July 20, 2026, so the proposed medical-monitoring claims did not receive certified-class status under that request.
Did the class-certification denial end the other Dixie Fire cases against PG&E?
No. The July 20, 2026 decision dealt with the proposed medical-monitoring class. PG&E reported approximately 190 complaints involving at least 9,062 individual plaintiffs as of July 15, 2026 and stated that a substantial majority of the broader claims had been resolved.
Atmospheric Sciences
Atmospheric dispersion modeling
Smoke Inhalation
Environmental Toxicology
Occupational And Environmental Health
Environmental hazards
Environmental Sampling
Environmental Medicine
Forest Fire
Utilities, +4
Utilities
Environmental Engineering, +4
Utilities