Acco Engineered Sys., Inc. v. Contractors' State License Bd., 30 Cal. App. 5th 80

Acco Engineered Systems replaced a commercial boiler in 2011–2012 without obtaining a Los Angeles permit; it later applied for and obtained the permit in 2014 after the Board's investigation.
The Contractors' State License Board cited Acco under Bus. & Prof. Code § 7110 for "willful or deliberate disregard and violation of the building laws," imposing a civil penalty reduced to $200 by the ALJ.
ALJ found Acco admitted permits were required and the project manager knowingly proceeded without consulting the company permit coordinator despite internal instructions—characterizing that as "willful."
Acco petitioned for writ of administrative mandamus (Code Civ. Proc. § 1094.5), arguing § 7110 requires specific intent to violate the law (not mere general intent or inadvertence) and that the record lacked substantial evidence of willfulness.
The trial court and the Court of Appeal rejected Acco's interpretation, held that "willful" requires only general intent (per Penal Code § 7(1) precedent), and found substantial evidence that Acco willfully disregarded building laws.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Meaning of "willful" in § 7110	"Willful" requires specific intent to violate building laws; inadvertent employee mistake is not enough	"Willful" requires only general intent to commit the act (Penal Code § 7(1)); specific knowledge of illegality not required	Court: "Willful" = general intent; specific intent not required
Whether the record supports willfulness	Failure to obtain permit was inadvertent mistake by a low-level employee; no substantial evidence of willful misconduct	Company manager affirmatively decided to proceed without consulting permit coordinator; corporate responsibility attaches	Court: Substantial evidence supports finding of willful disregard by Acco
Whether § 7110 becomes strict liability under general-intent reading	General-intent reading would render § 7110 meaningless and convert it to strict liability	General-intent reading is consistent with License Law scheme and exemptions exist (e.g., reasonable efforts to obtain permit; ambiguous local requirements)	Court: Not strict liability; general-intent reading harmonizes with statutory scheme
Relevance of corporate supervisory obligations	Corporate good-faith defenses excused liability for employee error	Licensee (and its responsible managing officer) is charged with supervising and ensuring compliance; employee acts are attributable to corporate licensee	Court: Corporate responsibility and § 7068.1 support attributing employee conduct to Acco

Handyman Connection of Sacramento, Inc. v. Sands, 123 Cal.App.4th 867 (discusses substantial-evidence review in license citation cases)
Yamaha Corp. of America v. State Bd. of Equalization, 19 Cal.4th 1 (agency statutory interpretation has contextual persuasive weight)
Viking Pools, Inc. v. Maloney, 48 Cal.3d 602 (License Law construed to protect consumers; reasonable and practical construction)
Mickelson Concrete Co. v. Contractors' State License Bd., 95 Cal.App.3d 631 (applies Penal Code § 7(1) definition of willful in License Law context)
Tellis v. Contractors' State License Bd., 79 Cal.App.4th 153 (discusses willfulness under § 7109 and evidentiary proof of knowledge)
Kwan v. Mercedes-Benz of North America, Inc., 23 Cal.App.4th 174 (distinct statutory context where jury should consider good-faith belief; limited to that scheme)
Housing Development Co. v. Hoschler, 85 Cal.App.3d 379 (administrative proceedings under License Law aimed at protecting public interest)
People v. Licas, 41 Cal.4th 362 (criminal willfulness cases do not require specific intent)
Rappleyea v. Campbell, 8 Cal.4th 975 (relief where party reasonably relied on official misinformation)
Dahlman v. State Bar, 50 Cal.3d 1088 (willful violation of professional rules does not require bad faith or actual knowledge)

Disposition: Judgment affirming denial of Acco's writ petition; costs to the Board.