CONSTRUCTION DEFECT JOURNAL

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Staffing Company Not Entitled to Make a Claim Against a Payment Bond and Attorneys’ Fees on State Public Works Payment Bonds

Glasses lying on Payment Bond

The California Department of Transportation awarded VSS International, Inc. two public works construction contracts for road maintenance.

August 12, 2024
Garret Murai - California Construction Law Blog

It’s not quite Baskin Robbin’s “31 Flavors” but the panoply of statutory construction payment remedies available to contractors, subcontractor and material suppliers in California, from mechanics liens to stop payment notices to payment bond claims, can be tempting to reach for when you are not paid. However, some flavors are more readily available than others, as a staffing agency discovered in K & S Staffing Solutions, Inc. v. The Western Surety Company, Case Nos. C096705 and C097987 (January 2, 2024).

The K & S Staffing Case
The California Department of Transportation awarded VSS International, Inc. two public works construction contracts for road maintenance. Each involved an expenditure of over $25,000 and VSSI obtained a payment bond from Western Surety Company.

Titan DVBE Inc. was a subcontractor on both projects. For most years, Titan employed its own workers. However, when it learned that its insurance carrier would no longer be offering workers’ compensation insurance in California it switched to K & S Staffing Solutions, Inc. to fulfill its staffing needs.

Mr. Murai may be contacted at gmurai@nomosllp.com