Eliason v. School District

54 Pa. D. & C.2d 52, 1970 Pa. Dist. & Cnty. Dec. LEXIS 12
CourtPennsylvania Court of Common Pleas, Delaware County
DecidedDecember 22, 1970
Docketno. 6494 of 1969
StatusPublished
Cited by1 cases

This text of 54 Pa. D. & C.2d 52 (Eliason v. School District) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Delaware County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Eliason v. School District, 54 Pa. D. & C.2d 52, 1970 Pa. Dist. & Cnty. Dec. LEXIS 12 (Pa. Super. Ct. 1970).

Opinion

REED, JR., J.,

This is a taxpayers’ suit to declare void an alleged contract between the School District of Springfield and the architectural firm of Stewart, Noble, Class and Partners.

This suit raises the issues of:

1. Whether a contract for architectural services must be advertised and bid.

2. In what manner must the school board enter into a contract for architectural services.

3. Must provisions respecting workmen, minimum wages, or nondiscrimination be included in such a contract.

The School District of Springfield is of the third class and its board of school directors consisted of seven members at all relevant times. On December 11, 1967, the school board, at a public meeting at which six school directors were present, adopted a resolution to engage the architectural firm of Stewart, Noble, Class & Partners as architects for the preparation of plans and specifications for additions and alterations to the Springfield Senior High School. After completion of plans and specifications, the contract was sub[54]*54sequently to be assigned to the school district authority which would then reimburse the school district for amounts paid to the architect. The minutes of this meeting indicate that all members of the board present voted for the resolution. Shortly thereafter, the architectural firm sent a contract form to the Superintendent of the Springfield Township School District.

On February 16,1968, this contract was signed, pursuant to the resolution of December 11, 1967, for the school district by Richard D. Carter and Elizabeth L. Pusey, the president and secretary, respectively, of the board of school directors, and by Frederick A. Long, who executed the instrument in the name of the architects. Richard D. Carter was the president of the school board and was present at the meeting of December 11, 1967.

On August 11, 1969, this contract was assigned to the school district authority, pursuant to the resolution. The contract form used for the contract in question was the standard form of agreement as prepared by the American Institute of Architects and the charges set forth therein were the same or even less than the fees prescribed by the Pennsylvania Society of Architects; six percent of new construction and 10 percent of alterations. We find both the fees and the time of payments as being reasonable.

The architectural firm was paid $119,055 by the school district on six invoices for portions thereof submitted to and approved by the school board. Subsequently, the school district was repaid this amount by the school district authority. Invoices went through the business office where a check was prepared but unsigned, and the item thereafter forwarded to the school board for approval before issuance of the check.

The board members did not actually see the contract form executed by the parties. Only Mr. Carter, Mrs. [55]*55Pusey and Dr. Grove, the superintendent, were present at its signing. The board members did not actually have the invoices brought specifically to their attention at the meetings of the school board.

The first of plaintiffs’ main contentions is that the contract for architectural services should only be awarded upon advertising and the submission of bids. Plaintiffs advance the theory that section 751 of the Public School Code of March 10, 1949, P. L. 30, 24 PS §7-751, requires this procedure (as it clearly does for building contracts) with regard to architectural services, since the statute says that:

“All construction, reconstruction, repairs or work of any nature . . .” shall be entered into with the lowest responsible bidder. (Italics supplied.)

The reported cases prior to the 1949 Act all indicate that under the preceding 1919 Act the architect’s contract did not have to be awarded on bids: Hibbs et al. v. Arensberg et al., 276 Pa. 24, 119 Atl. 727 (1923); Stratton v. Allegheny County, 245 Pa. 519; Philadelphia County v. Pittsburgh, 253 Pa. 147; and Sheets et al. v. Armstrong et al., 307 Pa. 385.

We see no change in the Act of 1949 which indicates any change in this rule, nor have plaintiffs cited any case in support of such a notion. “Work of any nature” does not include professional services, and never has with regard to municipalities.

The board should be free to choose the best available services for the drawing of plans for construction work; the contracts for such construction must be advertised for bids. Requiring advertisement and bid procedure to enter into contracts for professional services has never been public policy for the obvious reason that it could well lead to a lessening in quality of the services necessary, without any proportionate savings, and perhaps with the unwanted result of increas[56]*56ing the cost of the construction contract which is the matter of prime concern. We, therefore, find that the architect’s contract does not have to be advertised and bid upon.

Upon the removal of this keystone argument, the rest of plaintiffs’ argument falls.

The following section, section 752 of the Public School Code of 1949, 24 PS 7-752, requires that “all contracts” must have a stipulation or provision that only “competent and first class workmen and mechanics” shall work on the job. It would be a useless gesture to put such a provision in the architect’s contract, because the architect does not use workmen and mechanics. Aside from that, it is obvious that section 752 refers only to contracts let on bids pursuant to section 751. Since this was not such a contract, section 752 cannot apply. The same is true of plaintiffs’ arguments as to stipulations for minimum wages, provisions requiring residency by workmen and prohibition against discrimination, all of which by their own terms do not apply to this contract and which would only apply to a type of contract which must be let on bids under section 751.

The only remaining argument of plaintiffs is that even if the bid procedure is not required to contract for architectural services, still this contract is void for two reasons.

A. The resolution authorizing the contract was not properly adopted because its adoption was violative of a section of the Public School Code because it was not by roll call vote recorded.

The Public School Code of 1949, 24 PS 5-508, in part, provides as follows:

“The affirmative vote of a majority of all the members of the board of school directors in every school district, duly recorded, showing how each member voted, [57]*57shall be required in order to take action on the following subjects:

“Entering into contracts of any kind, including contracts for the purchase of fuel or any supplies, where the amount involved exceeds one hundred dollars ($100).

“Fixing salaries or compensation of officers, teachers, or other appointees of the board of school directors.

“Failure to comply with the provisions of this section shall render such acts of the board of school directors void and unenforcible.”

The school board vote in December 1967 was duly recorded within the act, since all six members present voted for the resolution: there was no need to record each vote separately; there is no question who voted for it; all six did: Spann v. Joint Boards of School Directors, 381 Pa. 338, 113 A. 2d 281, (1955).

B.

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Related

Kennedy v. Ringgold School District
309 A.2d 269 (Commonwealth Court of Pennsylvania, 1973)

Cite This Page — Counsel Stack

Bluebook (online)
54 Pa. D. & C.2d 52, 1970 Pa. Dist. & Cnty. Dec. LEXIS 12, Counsel Stack Legal Research, https://law.counselstack.com/opinion/eliason-v-school-district-pactcompldelawa-1970.