Christiansen v. Mechanical Contractors Bid Depository

230 F. Supp. 186, 1964 U.S. Dist. LEXIS 9023, 1964 Trade Cas. (CCH) 71,137
CourtDistrict Court, D. Utah
DecidedJune 3, 1964
DocketC 44-63
StatusPublished
Cited by7 cases

This text of 230 F. Supp. 186 (Christiansen v. Mechanical Contractors Bid Depository) is published on Counsel Stack Legal Research, covering District Court, D. Utah primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Christiansen v. Mechanical Contractors Bid Depository, 230 F. Supp. 186, 1964 U.S. Dist. LEXIS 9023, 1964 Trade Cas. (CCH) 71,137 (D. Utah 1964).

Opinion

CHRISTENSEN, District Judge.

The plaintiff, a mechanical specialty contractor, 1 has sued the defendant, The Utah Mechanical Contractors Bid Depository, 2 for damages and injunctive relief in reliance upon the Sherman AntiTrust Act, 15 U.S.C. §§ 1, 2, and § 15. The members of the Depository comprise a majority of the mechanical contractors in the State of Utah, and receive most of the important mechanical contracts bid within the State. The controversy mainly involves the validity of rules under which general contractors obtain sub-bids through the Depository.

Detailed Findings of Fact and Conclusions of Law are being filed with this Memorandum Decision; they may be deemed supplemented by the views herein expressed. It is sufficient now to state only limited background for explanation and resolution of the legal questions presented.

The Depository was organized for the avowed purpose “to promote the principles of competitive free enterprise and *188 to eliminate as far as possible unfair bidding practices. * * * ” Among the practices against which relief was sought were those termed “bid shopping and bid peddling”. Members submitted their bids to general contractors through the Depository under regulations which were designed to discourage direct negotiations for lower prices. General contractors accepting bids through the Depository were required to let these mechanical subcontracts to Depository members. 3 The latter restrictive provisions incorporated by amendment on November 12, 1962, together with certain other supplementing provisions, were unacceptable to the plaintiff, who had theretofore been a member and officer of the Depository. Fie thereupon discontinued his affiliation and later sued for damages to his business as a mechanical contractor.

Plaintiff claims that the rules in question are in restraint of trade and tend to create a monopoly. He further asserts that the administration of the Depository has been arbitrary and unfair, that opportunity has been afforded for collusion between bidders, with the result that general contractors do not necessarily secure the benefit of the lowest bids; that mechanical contractors can determine in advance who is bidding a particular project and that they have opportunity to tamper with the price or rig their bids, and that other abuses beyond the purport of the rules of the Depository have been perpetrated.

I have concluded that the latter contentions have not been sufficiently sustained, beyond the purport and expressed intent of the formal Depository rules themselves, to establish Sherman Act liability. 4 In fact, in some respects the administration of the rules was businesslike, circumspect and considerate. Evidence of minor abuses was sufficient to-suggest that the Depository plan involved certain disadvantages even to members, and was to a degree ineffectual to curb-bid shopping and peddling, thus mitigating the necessity and reasonableness of the specific rules under attack. The rules themselves, however, constitute the agreement or combination in restraint, of trade or in furtherance of monopoly upon which liability, if it exists, primarily must be founded. To their specific provisions we now turn. 5

Under the rules and regulations of the defendant corporation, general contractors who desire mechanical bids from; the Depository are required to request such bids at least forty-eight hours prior to the time set for bid openings. Rule V further provided; 6

“It is to be explicitly understood that the depository will forward bids, to general contractors making request therefor with the understanding that the general contractor will use only bids thus received from the-depository in preparing his bid. * * * >’

A form for required use by the general contractor in requesting bids from the Depository contains the following: undertaking:

“We are familiar with the depository rules numbers five, six and seven (as revised on November 12,. *189 1962) regarding the request for, and the acceptance of depository bids, and agree to comply therewith”.

The rules of the Depository further provide:

“Any member, after a hearing, and who has been found by a majority of the committee to have failed to comply with the rules and regulations of the depository, may be assessed a sum not to exceed $300.00 for each specific violation. Also, upon recommendation by the committee he may be suspended from the depository, and further membership denied. General contractors found to have been engaged in unfair bidding practices, or rules violations, may only upon recommendation by the committee, continue to use the services of the depository as long as they comply with the rules and regulations of the depository”.
Rule III provided as follows:
“All bids must be submitted on forms supplied by the depository. * * * It is the intent of the depository to provide complete mechanical quotations on all projects bid. Bid splitting such as plumbing only, heating only, etc. will not be acceptable”.
Rule VIII (of the revision) provides:
“After bids for a specific project have been opened, there shall be no further bidding on said project for a period of 90 days, by members who did not submit bids in the first instance, unless plans and specifications have been revised in an amount exceeding 25% of the value of work and materials shown on the original plans and specifications”.

Other provisions of the Depository rules are under attack. Apart from their support and implementation of Rules III, V and VIII quoted above, I do not think that they have exceptional antitrust implications. No ruling is made, however, as to their validity in other context.

I have concluded in view of established principles 7 that the three rules specifically referred to, representing as they do^ an agreement of the Depository with its members and the general contractors requesting Depository bids, implemented and activated, as the evidence shows they have been, by the concerted program of the Depository and its officers and committees, constitute a conspiratorial contract and combination in restraint of interstate commerce. They are thus proscribed by § 1 of the Sherman Act. I am also of the opinion that by means of the rules specifically referred to, the defendant corporation has attempted to monopolize, and has conspired with other persons to monopolize, a part of the commerce among the several states, contrary to § 2 of the Act.

The Depository argues that these restraints are reasonable and thus justified by a rule of reason. 8

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
230 F. Supp. 186, 1964 U.S. Dist. LEXIS 9023, 1964 Trade Cas. (CCH) 71,137, Counsel Stack Legal Research, https://law.counselstack.com/opinion/christiansen-v-mechanical-contractors-bid-depository-utd-1964.