RECENT CALIFORNIA DECISIONS

January 2006

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First District Revisits Prevailing Wage Law in Connection with Redevelopment Agency’s Reimbursement of Land Acquisition Costs to Developer
Greystone Homes, Inc. v. Chuck Cake, Unpub. Op.

On November 22, 2005, the First District Court of Appeal rendered an unpublished decision finding that a redevelopment agency’s reimbursement of land acquisition costs to a developer did not constitute the payment of public funds for construction activities requiring the payment of prevailing wages under the former (pre-2001) version of California’s Prevailing Wage Law (Labor Code §1720 et seq.). Although unpublished decisions do not normally deserve great attention, the California Redevelopment Agency and at least one building industry entity are requesting publication of the decision. If the Court of Appeal does decide to publish the case, the decision will play an important role in defining public works projects under the former and current versions of the Labor Code.