PLD-PI-001, the California personal injury complaint

PLD-PI-001, "Complaint—Personal Injury, Property Damage, Wrongful Death", optional use, revised January 1, 2024. This page explains what each part of the form asks for. It does not tell you what to write in it, and it is not legal advice. The official form.

The most important thing about this form

It is a shell. Item 10 says it in the form's own words — "each complaint must have one or more causes of action attached" — and lists the six attachments by name. Filed on its own, PLD-PI-001 identifies the parties and the court and alleges essentially nothing. The allegation that turns it into a legal claim is on a separate sheet.

The six cause of action attachments.

The caption block

The top third of page 1 is the same on every Judicial Council pleading. It asks for the attorney or the party appearing without one, with a state bar number, firm name, street address, city, state, zip, telephone, fax and email; then who that person appears for. Below it, the Superior Court of California for a named county, with the court's street address, mailing address, city and zip, and branch name. Then the plaintiff, the defendant, and a line reading "DOES 1 TO", followed by a case number the clerk assigns on filing.

The two check-box strips above item 1

Directly under the title the form asks two things that decide how the case is handled before a single fact is alleged.

• Type. Boxes for Motor Vehicle and for Other, with a space to specify; then Property Damage, Wrongful Death, Personal Injury, and Other Damages with a space to specify. More than one can apply. There is also an "AMENDED (Number)" box, used when this complaint replaces an earlier one.
• Jurisdiction. Boxes electing a limited civil case or an unlimited civil case, with the statutory amount printed beside each; a pair of boxes recording whether the amount demanded is above or below a lower figure; and boxes for reclassifying an existing case from limited to unlimited or unlimited to limited. What actually differs between the two tracks.

Items 1 to 9 — the parties and the court

1. Plaintiff

Names the plaintiff or plaintiffs bringing causes of action against the named defendant or defendants.

2 and 3. Capacity of each plaintiff

Item 3 begins "Each plaintiff named above is a competent adult" and then offers exceptions for each plaintiff in turn: a corporation qualified to do business in California, an unincorporated entity with a space to describe it, a public entity with a space to describe it, a minor — with separate boxes for an adult and a minor — and other, with a space to specify.

4. Fictitious business name

Records that the plaintiff is doing business under a fictitious name, with a space for the name.

5. Capacity of each defendant

The mirror of item 3, repeated four times over for defendants a through d. Each block starts from "a natural person" and offers, as exceptions: a business organization of unknown form, a corporation, an unincorporated entity, a public entity, and other. The form also carries a line about compliance with the fictitious business name laws.

6 and 7. Doe defendants

Item 6 records that the true names of defendants sued as Does are unknown to the plaintiff, with spaces for the Doe numbers and for whether they were agents or employees of other defendants. Item 7 records Does whose capacities are unknown. How Doe defendants work.

8. Why this court

A short list of reasons the court is the proper one, including that at least one defendant now resides in its jurisdictional area, with an "other" line. The form also references defendants joined under Code of Civil Procedure section 382.

9. Government claims

Records that the plaintiff is required to comply with a claims statute, and then either that they have complied with the applicable claims statutes, or that they are excused from complying, with a space to say why. This is the box that matters when a public entity is a defendant. Claims against a government entity.

Items 10 to 15 — what is alleged and what is asked for

10. Causes of action attached

Boxes for Motor Vehicle, General Negligence, Intentional Tort, Products Liability, Premises Liability and Other, with the form's own note that each complaint must have one or more attached.

11. What the plaintiff has suffered

A checklist, all that apply: wage loss, loss of use of property, hospital and medical expenses, general damage, property damage, loss of earning capacity, and other damage with a space to specify.

12 and 13. Further allegations

Space for damages that are listed in an attachment or set out as follows, so that anything the checklist does not cover can be stated.

14. The prayer

What the plaintiff asks the court for: compensatory damages and punitive damages, with the note that the amount of damages is "according to proof". That phrase is doing real work — see below.

15, date and signature

An amount line used where the law permits one to be stated, then the date, printed name and signature of the plaintiff or the attorney.

Why the form will not let you write down a number

In a personal injury or wrongful death action the law is explicit: the amount demanded shall not be stated in the complaint. That is why item 14 says "according to proof" rather than giving a box for a figure. It is not an oversight and it is not a tactic.

The defendant is not left guessing. They can request a statement of damages at any time, and the plaintiff has fifteen days to respond. Where no request is made, a statement still has to be served before a default can be taken against them.

Common questions

Is PLD-PI-001 a complete complaint?

No, and the form says so on its face. Item 10 reads "each complaint must have one or more causes of action attached". On its own the form states who is suing whom and little else — the allegation that makes it a legal claim is on the attachment.

Do I have to use this form?

No. Its own footer says "Form Approved for Optional Use". A complaint drafted from scratch is equally valid, and in a case with any complexity that is usually what gets filed. The form exists because the Judicial Council is authorised to publish pleading forms, not because it is required.

Why is there nowhere to write what the case is worth?

Because in a personal injury or wrongful death action the law says the amount demanded must not be stated in the complaint. Item 14 asks for compensatory damages "according to proof" instead. The defendant can request a separate statement of damages.

The complaint I was served says "DOES 1 TO 25". What does that mean?

It is a placeholder for defendants whose names are not yet known. Items 6 and 7 on this form record that they exist and why. If a real name emerges later, the plaintiff can amend to substitute it.

Sources: PLD-PI-001, Complaint—Personal Injury, Property Damage, Wrongful Death, Judicial Council of California, optional use, revised January 1, 2024, authority Code of Civil Procedure, § 425.12 — item text read from the published form, retrieved 1 September 2026. Code Civ. Proc., § 425.10 (what a complaint must contain; subd. (b), amount not stated in a personal injury action); Code Civ. Proc., § 425.11 (statement of damages on request, and before default); Code Civ. Proc., § 425.12 (authority for the form).