Subcontractor’s Bond Claim Revived Despite Timing Challenge

In Tarlton & Sons, Inc. v. Great American Insurance Co. (2025), the California Court of Appeal reinstated a subcontractor’s claim on a public works payment bond, rejecting the trial court’s finding that it was filed too late.

The court held that the statute of limitations hinges on when all work under the bonded contract ceases—not just the subcontractor’s work. Because that date was unclear, the issue couldn’t be resolved on demurrer.

Key Takeaway: Timing for public bond claims depends on when all work on the bonded contract work stops—not just when a subcontractor finishes.