Ball v. Steadfast-BLK, 126 Cal. Rptr. 3d 743

Ball held a CSLB license as a sole owner (sole proprietorship) for Clark Heating and Air Conditioning; the contracts were entered as David E. Ball, dba Clark Air Conditioning & Heating; a mechanic’s lien was recorded identifying Clark Air Conditioning & Heating as claimant and Ball signed as owner; Steadfast demurred to foreclose on the lien arguing the name was unlicensed; trial court held Ball was precluded under §7031(a) due to name discrepancy; court of appeal reversed, clarifying the license covers the contracting name and name discrepancy is disciplinary, not jurisdictional.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether §7031(a) bars Ball from foreclosing the lien.	Ball was licensed at all times.	Ball did not contract in exact license name.	Not barred; license permits work under Ball’s name.
Whether operating under a DBA name distinct from the license name bars the action.	Name discrepancy is a technical violation, not fatal.	Name discrepancy undermines licensure alignment.	Discrepancy is disciplinary, not a bar to relief.
Whether a sole proprietor and contracting party may foreclose a lien recorded under a DBA.	Ball is the contracting party and licensee; lien is against him.	Lien recorded under a DBA; entity issue.	Ball may foreclose; Clark Air Conditioning & Heating not a separate entity.

Hydrotech Systems, Ltd. v. Oasis Waterpark, 52 Cal.3d 988 (Cal. 1991) (licensing as bar to compensation for unlicensed work; public policy)
MW Erectors, Inc. v. Niederhauser, 36 Cal.4th 412 (Cal. 2005) (7031(a) bars recovery when licensure not at all times during performance)
Opp v. St. Paul Fire & Marine Ins. Co., 154 Cal.App.4th 71 (Cal. App. 2007) (entity contracting issues with licensee principals)
Pinkerton’s Inc. v. Superior Court, 49 Cal.App.4th 1342 (Cal. App. 1996) (business name is fiction; not a separate entity)
Providence W. Ins. Co. v. Valley Forge Ins. Co., 42 Cal.App.4th 1194 (Cal. App. 1996) (corporate/ownership distinctions in licenses)