LA Fires,
Civil Litigation
Aug. 12, 2025
Deaths from wildfires continue after blazes put out, attorneys say
Attorneys say deaths from January's Eaton and Palisades wildfires continue mounting, with clients dying later from stress and smoke-related health issues--potentially raising liability in ongoing wrongful death lawsuits.





Several plaintiffs in the Eaton and Palisades fire cases have died in the aftermath of the blazes from health problems exacerbated by the wildfires, increasing the wrongful death claims, according to their attorneys.
James P. Frantz said one of his clients suffered pulmonary failure after ingesting smoke and ash from the Palisades Fire. That client had a preexisting condition from cigarettes, and died within three or four days of the fire. Frantz Law Group also has at least two death cases stemming from the Eaton Fire, in which their clients survived the fire only to die from smoke and ash shortly thereafter.
"One guy survived five days after the fire," Frantz remarked.
Other attorneys shared similar stories. But much of the narrative surrounding the January wildfires in Los Angeles County focuses on the scale of the destruction and the 31 deaths that were immediately linked to the fires. A report published by the Journal of the American Medical Association attributed 440 deaths to factors exacerbated by the fires. That would be nearly 15 times higher than the official death count.
The researchers analyzed deaths recorded in Los Angeles County over a four-week stretch starting Jan. 5, and compared that data with the same period in previous years. They found a 6.9% increase in "all-cause" mortality that researchers attributed to the wildfires.
"I'm not at all surprised there were over 400 people that perished from the fires," Edelson PC partner Ali Moghaddas said. "We have lots of clients who didn't die that night but shortly thereafter. Doctors did autopsies and said it was trauma from the fire, smoke inhalation."
Those cases become wrongful death cases by the estate, Moghaddas continued.
In the case of the Eaton Fire, plaintiffs would have to establish that defendant Southern California Edison wrongfully caused those deaths.
"It's one thing to look at it on a macro level and say we believe there have been 400 additional cases. It's different to prove in a court of law 'but for the fire,'" Singleton Schreiber's managing partner, Gerald Singleton said. "We would look at medical evidence, talk to their doctors, based on evidence in this specific case and based on certainty the fire was a cause of their death."
Foley Bezek Behle & Curtis partner Roger N. Behle Jr. said one of their clients died on Thursday from health and stress issues caused by the fire.
"Every case stands on its own," Behle said. "The facts unique to the death cases will include expert analyses that won't be there for property or emotional damages cases. Each death case will involve a whole other range of issues."
Behle's firm, Robertson & Associates LLP, and Gandhi Law Group collectively represent some 3,300 plaintiffs in the Eaton and Palisades cases.
The Eaton Fire cases are related to lead case Gursey v. Southern California Edison, 25STCV00731 (L.A. Super. Ct., filed Jan. 13, 2025).
The Palisades Fire cases are related to lead case Grigsby, et al. v. City of Los Angeles acting by and through the Los Angeles Department of Water and Power, 25STCV00832 (L.A. Super. Ct., filed Jan. 13, 2025).
Antoine Abou-Diwan
antoine_abou-diwan@dailyjournal.com
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