Mangrove Jack's sell repacked Kölsch yeast under the "Californian Lager" label solely because of marketing considerations. Same as with "New World Strong Ale", "Liberty Bell" and "Verdant IPA", three classic English strains that have little historical connection to the New World despite being labeled now (quite recently) with distinctly American names.
The distinction between S. cerevisiae as "Ale" and S. Pastorianus as "Lager" yeasts is actually quite a recent and far from a universal concept. Germans f.ex. would hardly call Kölsch an "ale", for them it's a "top-fermented Lager" because it's lagered (cold-conditiomed), irregardly of the yeast species used.
California Common aka Steam Beer aka California Lager is exactly a "top-fermented Lager", so technically Mangrove Jack's don't mislead their customers with the "Lager" wording in the label. Which they actually do, even though they don't make a secret that M54 is a Cerevisiae, not Pastorianus, strain.