## Facts

- Vista voters approved a local sales tax increase to finance municipal capital projects, including fire stations and a civic center.
- Vista transitioned from a general law city to a charter city after advice that charter status would allow locally funded public works contracts without state prevailing wage requirements, reducing project costs.
- After adopting its charter, Vista awarded and executed locally funded public works contracts that did not require contractors to pay state-determined prevailing wages.
- A construction trade union federation sought a writ of mandate compelling Vista to comply with California’s prevailing wage law for these projects.
- The trial court denied relief, and the Court of Appeal affirmed, treating the wage requirements on locally funded municipal construction as a charter-city municipal affair.

## Issues

1. Whether a charter city must comply with California’s prevailing wage law on municipal public works projects financed solely with local funds.
2. Whether the charter city’s determination of wage requirements for such contracts is a “municipal affair” that supersedes conflicting state law, or a matter of “statewide concern” permitting state preemption.

## Decision

- The California Supreme Court affirmed the denial of the writ of mandate.
- The Court held that, for a charter city, deciding whether to require prevailing wages on locally funded municipal public works is a municipal affair under the state Constitution’s home-rule provision.
- Because no sufficient statewide concern was shown to override charter-city autonomy in this context, the state prevailing wage statute did not apply to Vista’s locally funded projects.
- The Court limited its analysis to projects funded solely with local revenues and noted the state may condition its own funding on prevailing wage compliance.

## Legal Principles

- When a charter-city enactment conflicts with a state statute, courts apply a home-rule conflict analysis: identify the local subject, confirm conflict, determine whether the subject is a municipal affair or statewide concern, and (if statewide concern) assess whether the state law is reasonably related and narrowly tailored to that concern.
- Public works contracting and decisions about expenditure of a charter city’s local revenues for municipal improvements are generally municipal affairs.
- State law may displace charter-city control only if the state demonstrates a bona fide statewide concern sufficient to justify intrusion into municipal affairs.

## Conclusion

The court held that a charter city may omit state prevailing wage requirements from public works contracts financed exclusively with local funds because setting wage terms for such locally funded municipal construction is a municipal affair that prevails over conflicting state law absent a demonstrated overriding statewide concern.


State Bldg. & Constr. Trades Council of Cal., AFL-CIO v. City of Vista, 54 Cal. 4th 547, 279 P.3d 1022 (Cal. 2012)