Delaware River Joint Toll Bridge Commission v. George Harms Construction Co., Inc.

CourtSupreme Court of New Jersey
DecidedAugust 1, 2024
DocketA-55-22
StatusPublished

This text of Delaware River Joint Toll Bridge Commission v. George Harms Construction Co., Inc. (Delaware River Joint Toll Bridge Commission v. George Harms Construction Co., Inc.) is published on Counsel Stack Legal Research, covering Supreme Court of New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Delaware River Joint Toll Bridge Commission v. George Harms Construction Co., Inc., (N.J. 2024).

Opinion

SYLLABUS

This syllabus is not part of the Court’s opinion. It has been prepared by the Office of the Clerk for the convenience of the reader. It has been neither reviewed nor approved by the Court and may not summarize all portions of the opinion.

Delaware River Joint Toll Bridge Commission v. George Harms Construction Co., Inc. (A-55-22) (088194)

Argued January 3, 2024 -- Decided August 1, 2024

WAINER APTER, J., writing for a unanimous Court.

In this appeal, the Court considers whether the Delaware River Joint Toll Bridge Commission (Commission), a bi-state entity created through an interstate compact (Compact) between New Jersey and Pennsylvania, may require potential bidders to use project labor agreements (PLAs) as part of its public bidding process.

In 1934, New Jersey and Pennsylvania jointly created the Commission through the Compact to construct, acquire, administer, operate, and maintain certain bridges across the Delaware River. In 1935, Congress approved the Compact.

In 2009, the Commission approved a resolution to replace the existing I-95 Scudder Falls Bridge. After the Commission announced that it would accept sealed bids for the bridge replacement project, it authorized its Executive Director to enter into a PLA for the project. The Commission released the PLA publicly, as an addendum to the contract bid documents, in November 2016. The PLA required the selected contractor and all subcontractors to hire at least 75% of their project workforce from identified local unions.

The George Harms Construction Company, Inc. (Harms) is a construction contractor. At the time the Commission released its PLA, Harms was party to a collective bargaining agreement with the United Steel, Paper and Forestry, Rubber, Manufacturing, Energy, Allied Industrial and Services Workers International Union, AFL-CIO, CLC (USW), which precluded Harms from complying with the terms of the PLA. Harms requested that the Commission include USW in the PLA, or it would seek an injunction to prevent the project from moving forward.

The Commission filed a complaint against Harms seeking a declaration that it was entitled to proceed with the PLA it had issued. Harms asserted counterclaims, alleging that the PLA was unlawful because it excluded USW. Harms did not attack the Commission’s authority to enter into PLAs generally.

1 The trial court denied Harms’ request for a preliminary injunction, and the Commission awarded the project to the only bidder. The parties filed summary judgment motions, and the trial court held that New Jersey’s competitive bidding laws, which Harms claimed barred the use of the PLA, did not apply to the Commission. The court dismissed Harms’ counterclaims with prejudice but also dismissed the Commission’s complaint because it determined that the lawsuit “was not strictly authorized” by the Commission as a whole.

The Appellate Division affirmed the order dismissing the Commission’s complaint for different reasons and reversed the dismissal of certain counterclaims. 475 N.J. Super. 317, 360 (App. Div. 2023). The court held that the text of the Compact “is silent on PLAs” and therefore looked to the test in Ballinger v. Delaware River Port Authority, 172 N.J. 586 (2002). 475 N.J. Super. at 351-52. Because “New Jersey and Pennsylvania have not enacted complementary or parallel legislation or case law and do not have similar common law on PLAs,” the appellate court concluded that the Commission lacked the authority to use a PLA. Id. at 355.

The Court granted certification. 254 N.J. 523 (2023).

HELD: The plain language of the Compact authorizes the Commission to require the use of a PLA in a publicly bid construction project. The Commission’s ability to do so is not constrained by Ballinger.

1. Under the Compact Clause of the United States Constitution, each State possesses the sovereign authority to enter into a compact with another State, subject to Congress’s approval. Once Congress approves an interstate compact, the compact becomes the law of the Union. Ballinger’s complementary or parallel state law test and the Third Circuit’s express intent standard are two competing analyses for when a bi-state compact can be amended. Under Ballinger, “the subsequent laws of one compacting state will apply to a bi-state agency” if both states have “complementary or parallel” legislation on the topic in question or if “the common law” of the two states on the topic is “substantially similar.” 172 N.J. at 595-99. The Third Circuit rejected that test and held that subsequent legislation will amend an interstate compact only if both states “exhibit[] [an] express intent to amend the Compact” or apply the subsequent legislation to the interstate entity in question. Int’l Union of Operating Eng’rs, Loc. 542 v. Del. River Joint Toll Bridge Comm’n, 311 F.3d 273, 280 (3d Cir. 2002). (pp. 18-22)

2. The Court explains that although construction on the Scudder Falls Bridge is complete, the question of whether the Compact authorizes the Commission to use a PLA in one of its construction projects is “an issue of public importance that is capable of repetition yet evades review.” (pp. 22-23)

2 3. The Commission’s powers are determined first by the express terms of the Compact. Looking to the Compact’s plain text, New Jersey and Pennsylvania granted the Commission power to construct and replace bridges, “enter into contracts” to do so, “determine . . . all other matters in connection with, any and all improvements or facilities” it has the power to construct, and, with the exception of the “power to levy taxes,” “exercise all other powers . . . which may be reasonably necessary or incidental” to the Commission’s work. N.J.S.A. 32:8-3, -11; 36 Pa. Stat. Ann. § 3401. Taken together, these grants of authority are broad enough to encompass the power to require that a party with whom the Commission contracts to build a bridge sign a PLA. This is true even though the phrase “Project Labor Agreement” does not appear in the text of the Compact. And it is true even though New Jersey and Pennsylvania could not have contemplated the use of PLAs when they entered into the Compact in 1934 as PLAs did not yet exist. (pp. 23-25)

4. The New Jersey and Pennsylvania legislatures amended the statutes that constitute the Compact in 1994 and 1996, respectively, “to require the commission to competitively bid contracts in accordance with the public policies of” those states. N.J.S.A. 32:8-3.8(d); 36 Pa. Stat. Ann. § 3401.11(4). Congress, however, never approved those amendments, and it is thus not clear that the Compact itself was properly amended. Even assuming that it was, that language is not operative law; it is part of the legislative findings and declarations. The operative portion of the amendments require the Commission to publicly advertise for bids and award the contract to the lowest responsible bidder. The Commission fulfilled those two obligations for the Scudder Falls Bridge project. (pp. 26-28)

5. When two states confer a power on a bi-state entity within the four corners of an interstate compact, there is no basis to look beyond the compact, to other state laws of general applicability that do not mention the compact at all, to determine whether that power exists. Here, because the Compact’s text encompasses the authority to use a PLA, the Appellate Division erred in looking beyond the Compact to determine whether other New Jersey and Pennsylvania laws and policies that do not mention the Commission authorize the use of PLAs.

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Delaware River Joint Toll Bridge Commission v. George Harms Construction Co., Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/delaware-river-joint-toll-bridge-commission-v-george-harms-construction-nj-2024.