On November 18, 2025, the California Court of Appeal, Fourth Appellate District, issued a published decision in Anton’s Services Inc. v. Hagen, affirming administrative findings and penalties against a contractor for misclassifying workers, failing to pay prevailing wages, and violating apprenticeship requirements on public works projects. The decision does not make any new law, but it provides an important reminder on the strict enforcement of California’s Prevailing Wage Law and apprenticeship statutes, particularly concerning the importance of using the correct worker classification for the type of work performed. The decision also clarifies the standards for judicial review of administrative determinations.
Quick Hits
- On November 18, 2025, the California Court of Appeal affirmed penalties against Anton’s Services for misclassifying workers and failing to comply with prevailing wage and apprenticeship requirements on public works projects.
- The court’s decision highlights the strict enforcement of California’s Prevailing Wage Law, emphasizing the necessity of correct worker classification and adherence to apprenticeship statutes.
- The ruling clarifies that judicial review of administrative wage and penalty assessments is limited to the administrative record and governed by the substantial evidence standard.
Background
The case arose from two public works projects in San Diego County for road improvement and slope restoration. Anton’s Services was retained as a subcontractor on the slope restoration project, and its scope of work included “clearing and grubbing” the slope. The contractor was cited by the Division of Labor Standards Enforcement (DLSE) for misclassifying workers under the “Tree Maintenance” classification rather than the higher-paid “Laborer (Engineering Construction)” classification, failing to pay prevailing wages, and not complying with statutory apprenticeship requirements. The DLSE issued civil wage and penalty assessments for both projects, which the contractor challenged through administrative and judicial proceedings…