SACRAMENTO, Calif. - Construction companies failed to assert professional negligence and constructive fraud claims against an insurance broker regarding a failed workers' compensation program, a California appeals panel held March 10, affirming summary judgment in favor of the insurance broker (Mark Tanner Construction Inc., et al. v. HUB International Insurance Services Inc., No. C071176, Calif. App., 3rd Dist.; 2014 Cal. App. LEXIS 219).