State Building & Construction Trades Council v. City of Vista
54 Cal. 4th 547
| Cal. | 2012Background
- Charter city Vista repealed prevailing wage requirements for locally funded public works via ordinance after converting from general law to charter status.
- Union challenged Vista’s contracts by seeking a writ of mandate to enforce state prevailing wage law.
- Trial court denied the petition, citing Vial v. City of San Diego, and the Court of Appeal affirmed.
- California Constitution article XI, section 5 governs home rule, balancing municipal affairs against statewide concerns.
- Court applies California Fed. Savings four-part test to resolve whether state law applies to charter cities.
- Majority holds wage levels for locally funded public works are municipal affairs with no statewide concern; thus state law does not supersede Vista’s charter-based ordinance.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does the state prevailing wage law apply to charter cities? | Union asserts statewide concern and need for uniform wages. | Vista contends municipal affair not subject to state wage law. | No; wage levels on local works are municipal affairs; no statewide concern. |
| Is there an actual conflict between state law and Vista’s ordinance? | There is an express conflict as Vista ordinance disallows prevailing wages. | State law applies to public works, regardless of charter status. | Yes; actual conflict exists. |
| Does the prevailing wage law address a statewide concern? | Wage levels affect regional labor markets and training statewide. | State concern is not demonstrated; local fiscal autonomy matters. | No; no statewide concern justifies supersession in this case. |
| Is the four-part California Fed. Savings framework satisfied? | Extramunicipal benefits justify state regulation. | Municipal autonomy prevails; extramunicipal factors insufficient. | No; state interest not sufficiently compelling to override charter autonomy. |
Key Cases Cited
- California Fed. Savings & Loan Assn. v. City of Los Angeles, 54 Cal.3d 1 (Cal. 1991) (framework to resolve municipal affairs vs statewide concern; four-part analysis)
- Charleville (City of Pasadena v. Charleville), 215 Cal. 384 (Cal. 1932) (wage-related municipal affairs; foundational Charleville precedent)
- Vial v. City of San Diego, 122 Cal.App.3d 346 (Cal. App. 1981) (charter city wage decisions as municipal affairs; reliance disputed)
- Sonoma County Organization of Public Employees v. County of Sonoma, 23 Cal.3d 296 (Cal. 1979) (municipal vs statewide concern; local employee wages as municipal)
- S.F. Labor Council v. Regents of University of California, 26 Cal.3d 785 (Cal. 1980) (state wage law not controlling for charter/university autonomy)