Owen v. Sands

176 Cal. App. 4th 985, 98 Cal. Rptr. 3d 167, 2009 Cal. App. LEXIS 1374
CourtCalifornia Court of Appeal
DecidedJuly 28, 2009
DocketA121809
StatusPublished
Cited by11 cases

This text of 176 Cal. App. 4th 985 (Owen v. Sands) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Owen v. Sands, 176 Cal. App. 4th 985, 98 Cal. Rptr. 3d 167, 2009 Cal. App. LEXIS 1374 (Cal. Ct. App. 2009).

Opinion

*988 Opinion

BRUINIERS, J. *

A licensed contractor was cited for six violations of state contractor law and ordered to pay civil penalties and compensation to the injured homeowner. He challenged the citation, which was upheld by the Registrar of Contractors after an administrative hearing at which the violations were found true by a preponderance of the evidence. The contractor argues the standard of proof should have been clear and convincing evidence. We conclude the agency applied the correct standard of proof. We also reject the contractor’s contention that he was improperly convicted of criminal misdemeanors through an administrative proceeding, and his argument that the administrative hearing was procedurally flawed because no accusatory pleading was filed.

Background

The following facts are taken from the administrative law judge’s findings, which are not disputed for purposes of this appeal. On June 28, 2005, Timothy J. Owen verbally agreed to replace 18 windows, install a sliding glass door, and replace the front door in a Kensington home for $19,000. He performed the work in July and August 2005, even though his contractor’s license was not issued until September 2005. The homeowner asked other contractors to review the quality of Owen’s work, and it was found deficient. When the homeowner confronted Owen on the matter, he became angry, demanded more money, and ultimately abandoned the project. The homeowner hired another contractor to correct and complete the work at a cost of $13,265.

The Registrar of Contractors (Registrar) issued a citation to Owen alleging six violations of the Business and Professions Code: 1 (1) engaging in the business of contractor without a license (§ 7028); (2) willfully and materially departing from trade standards of good workmanship (§ 7109); (3) failing to correct or complete a project for the stated contract price, causing the owner to secure the services of another contractor (§ 7113); (4) failing to include required provisions in the contract (§ 7159); (5) willfully or fraudulently acting in a manner that substantially injured another (§ 7116); and (6) falsely claiming a workers’ compensation insurance exemption (§ 7125, subd. (b)).

*989 The citation imposed civil penalties totaling $1,600 and an order of correction requiring Owen to pay the homeowner $7,880.79.

Owen contested the citation and a hearing was held before an administrative law judge (ALJ) of the Contractors’ State License Board. Before the hearing commenced, Owen argued that the standard of proof at the hearing should be clear and convincing evidence, but the ALJ ruled the applicable standard of proof was preponderance of the evidence. Following four days of testimony, the ALJ found each of the alleged violations to be true, and increased the civil penalties to $2,000 after finding Owen’s conduct was deceitful, grave and egregious. The Registrar adopted the ALJ’s proposed decision in September 2007 and his decision became final in October.

In November 2007, Owen filed a petition for administrative mandamus asking the court to set aside the decision on the ground that the ALJ applied the wrong standard of proof. (Code Civ. Proc., § 1094.5.) After briefing, the trial court ruled that the preponderance of the evidence was the correct standard of proof and denied the petition.

Discussion

Owen argues the ALJ applied the wrong standard of proof, that the ALJ improperly convicted him of misdemeanors without criminal jurisdiction, and that the hearing was procedurally flawed because it was not initiated with a formal accusatory pleading. Because only legal issues are raised on appeal, our standard of review is de novo. (Steinsmith v. Medical Board (2000) 85 Cal.App.4th 458, 465 [102 Cal.Rptr.2d 115] (Steinsmith).)

I. Standard of Proof at the ALJ Hearing

Owen argues the standard of proof required in all professional or vocational license disciplinary proceedings is clear and convincing proof to a reasonable certainty. We conclude the preponderance standard was appropriate in the citation proceeding because the only potential sanctions were orders of correction and civil penalties.

Owen relies on a line of cases holding that the clear and convincing evidence standard of proof applies in proceedings to restrict, suspend or revoke professional or vocational licenses. In the lead case of Ettinger v. Board of Medical Quality Assurance, the court held that “the proper standard of proof in an administrative hearing to revoke or suspend a doctor’s license should be clear and convincing proof to a reasonable certainty and not a *990 mere preponderance of the evidence.” (Ettinger v. Board of Medical Quality Assurance (1982) 135 Cal.App.3d 853, 856 [185 Cal.Rptr. 601] (Ettinger).) Ettinger in turn relied on cases holding that this heightened standard of proof applies in proceedings to disbar an attorney or to suspend or revoke a real estate license. (Id. at p. 855, citing Furman v. State Bar (1938) 12 Cal.2d 212, 229 [83 P.2d 12] (Furman)] Small v. Smith (1971) 16 Cal.App.3d 450, 457 [94 Cal.Rptr. 136] (Small)] Realty Projects, Inc. v. Smith (1973) 32 Cal.App.3d 204, 212 [108 Cal.Rptr. 71] (Realty Projects)] see also Kapelus v. State Bar (1987) 44 Cal.3d 179, 184, fn. 1 [242 Cal.Rptr. 196, 745 P.2d 917] (Kapelus)] cf. San Benito Foods v. Veneman (1996) 50 Cal.App.4th 1889, 1892-1895 [58 Cal.Rptr.2d 571] [heightened standard of proof not required in proceeding to revoke nonprofessional food processing license]; Mann v. Department of Motor Vehicles (1999) 76 Cal.App.4th 312, 318-320 [90 Cal.Rptr.2d 277] [same, with respect to vehicle salesperson’s license].) Although Owen does not cite any case that holds the clear and convincing evidence standard of proof applies in a licensed contractor disciplinary proceeding, the Registrar does not dispute that the higher standard would apply in a proceeding seeking suspension, or revocation of a contractor’s license. (See Viking Pools, Inc. v. Maloney (1989) 48 Cal.3d 602, 605 [257 Cal.Rptr. 320, 770 P.2d 732] [noting that ALJ applied clear and convincing evidence standard in licensed contractor disciplinary hearing without addressing whether the higher standard was required].)

The question before us is whether the clear and convincing evidence standard also applies in a citation proceeding where the only proposed sanctions are a civil penalty or an order of correction, and which does not involve restriction, suspension, or revocation of a contractor’s license.

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Bluebook (online)
176 Cal. App. 4th 985, 98 Cal. Rptr. 3d 167, 2009 Cal. App. LEXIS 1374, Counsel Stack Legal Research, https://law.counselstack.com/opinion/owen-v-sands-calctapp-2009.