California is once again in the bottom tier of states for its business legal climate and Los Angeles was again named the least fair litigation environment of any metropolitan area, according to an annual ranking conducted by the Institute for Legal Reform and the Harris Interactive polling firm.

The survey of 1,600 senior attorneys from across the nation showed that California slipped one point in the ranking to 45 in 2006 from 44 in 2005, driven largely by high levels of certifications of class action lawsuits and large judgments in civil cases.

What’s more, “California is becoming a target for litigation tourism,” where plaintiffs’ lawyers file lawsuits on behalf of non-residents, said Tom Donohue, president and chief executive of the U.S. Chamber of Commerce, which supports litigation reform. Similar lawsuits were shut down in Mississippi and Texas after those states enacted limitations.

West Virginia was ranked as having the worst liability environment of any state in the nation, followed by Mississippi, Louisiana, Alabama and Illinois. Delaware, Minnesota, Nebraska, Iowa and Maine placed in the top five.

On the local level, 13 percent of attorney respondents ranked Los Angeles as having the “least fair and reasonable litigation environment” of any major metropolitan area in the nation, followed by the Chicago area. The survey did not ask for the cities or counties with the most fair and reasonable litigation environments.

Trial lawyers took issue with the survey.

“This latest propaganda is a made-up survey primarily of corporate lawyers earning millions of dollars defending their CEOs from being held accountable,” said Jon Haber, chief executive officer of the American Association for Justice. “The Chamber will stop at nothing to destroy the civil justice system in America, which protects the rights of consumers, employees, and shareholders against corporate wrongdoing and negligence.”