The 2011/2012 Judicial Hellholes report from the American Tort Reform Foundation identifies Philadelphia at the top of the list, followed by California, West Virginia and South Florida. Two counties in Illinois, Madison and St Clair, round out the top five. The top four do not appear to have changed from the 2010/2011 report but there has been some shifting around for fifth place. Cook County IL, the previous holder of fifth place, has been moved all of the way off the rankings to the watch list. The report reasons the lack of civil justice reform keeps it on the watch list but since it experienced a relatively low-key year, it was allowed to fall from fifth place. Of note, Madison County IL was previously on the watch list but moved clear up to a fifth place ranking due in part to the large number of asbestos related cases.