Employment Litigation · Primary-source case analysis

Kaanaana: Belt Sorting for a Public Sanitation District Was Public Work

By Aneeta Mishra and Timothy Chan

Published September 16, 2026

Kaanaana v. Barrett Business Services, Inc. concerned contract workers who removed recyclables and obstructions from conveyor belts at facilities operated for a Los Angeles County sanitation district.

The workers were supplied through a contractor

Barrett Business Services staffed the district facilities and supervised the belt sorters. Their contractual status did not by itself answer whether the tasks were public works for prevailing-wage purposes.

The governing definition covered work done for the district

The relevant Labor Code provision uses a broader formulation for irrigation, utility, reclamation, and other specified districts. The court interpreted work done for such a district to include the belt-sorting services at issue.

The court rejected a narrow construction limitation

The statutory text did not confine this district-specific category to construction or infrastructure installation. Another statutory exclusion for certain refuse hauling did not encompass the sorting performed inside the facilities.

The judgment for the workers was affirmed

The opinion established coverage under the applicable public-works definition. Wage calculations, class proof, and other claim elements remained subject to the record and governing enforcement rules.

Key takeaways

• Identify the public entity and the exact statutory definition that applies.
• Describe the work actually performed, not just the contractor’s label.
• Analyze statutory exclusions narrowly against their text.
• Preserve contracts, facility duties, payroll records, and applicable wage determinations.