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Contracts,
Construction,
California Courts of Appeal

Sep. 11, 2025

Summer reading: A swimming pool case with a cold splash of reality

In Stronghold Engineering v. City of Monterey (2023), the California Court of Appeal held that a contractor's initial lawsuit seeking only declaratory relief regarding a City contract did not require prefiling a Government Claims Act claim and that subsequent claims for monetary damages could be added after proper notice without being barred.

Garret D. Murai

Partner
Nomos LLP

Garret is the editor of the California Construction Law Blog at www.calconstructionlawblog.com.

See more...

Summer reading: A swimming pool case with a cold splash of reality
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Perhaps it comes as no surprise, but public entities enjoy special treatment under the law. One such protection is the Government Claims Act (Gov. Code § 810 et seq.), which generally requires a claimant to file a claim with the public entity before bringing suit.

But as the next case illustrates, that requirement is not absolute. In

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