California, and in particular Los Angeles and San Francisco, has one of the most unfair litigation environments in the country, according to a survey of general counsel released Wednesday by the U.S. Chamber of Commerce.

The annual nationwide survey of 1,599 in-house attorneys and senior litigators at companies with annual revenues of at least $100 million ranked California 45th among states based on criteria such as juries’ fairness, judges’ impartiality and punitive damages. Corporate attorneys rated only Illinois, Alabama, Louisiana, Mississippi and West Virginia as worse venues than the Golden State. Delaware, Minnesota and Nebraska received the highest scores in the survey.