Sheet Metal Workers’ Int'l Assn., Local 104 v. Duncan: Offsite Material Fabricators Not Subject to Prevailing Wage Law

A very quick note on this case.

In Sheet Metal Workers’ International Association, Local 104 v. Duncan (Russ Will Mechanical, Inc.) (8/27/14) --- Cal.App.4th ---, the Court of Appeal held that the prevailing wage law does not apply to an employee of a subcontractor who conducts offsite material fabrication if the work "takes place at a permanent, offsite manufacturing facility and the location and existence of that facility is determined wholly without regard to the particular public works project." Slip op. at 24.

The opinion is available here.