Families United of Washington County, Inc. v. Maine Dep't of Human Servs.

CourtSuperior Court of Maine
DecidedJune 20, 2002
DocketKENap-01-68
StatusUnpublished

This text of Families United of Washington County, Inc. v. Maine Dep't of Human Servs. (Families United of Washington County, Inc. v. Maine Dep't of Human Servs.) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Families United of Washington County, Inc. v. Maine Dep't of Human Servs., (Me. Super. Ct. 2002).

Opinion

STATE OF MAINE SUPERIOR COURT

CIVIL ACTION KENNEBEC, ss. DOCKET NO. AP-01-68 “Dh FAMILIES UNITED OF WASHINGTON COUNTY, INC., Petitioner Vv. DECISION AND ORDER MAINE DEPARTMENT OF DONALD L. GARBRECHT HUMAN SERVICES, et al., LAW LIBRARY Respondents JUL 18 2002

This matter is before the court on Families United of Washington County's 80C petition for review of final agency action denying its appeal of a contract award by the Department of Human Services.

Families United of Washington County (Families) is an organization that provides a variety of support and mental health services to families in Washington and Hancock Counties. In February 1998, the Maine Department of Human Services (DHS) issued a Request for Proposal (RFP) seeking bids for the award of a contract to provide domestic violence response services in Washington County. The evaluation process implemented by the Division of Purchases and Support Services rated the proposals using numerically-scored evaluation criteria. DHS awarded the contract to Washington-Hancock County Agency (WHCA) with petitioner rated lowest in the process. Families filed a timely appeal of the contract award decision alleging problems with the reviewing process along with biased and arbitrary scoring which it says resulted in an arbitrary or capricious award. The Appeal Committee convened by Department of Administrative and Financial Services (DAF) agreed with Families and,

per statutory authority, invalidated the contract award to WHCA. Concluding that there was no evidence that there was any flaw in the original. REP or that there were subsequent events or circumstances that rendered the proposals invalid, DHS decided that it would not issue a new RFP but rather chose to re-submit the old proposals to a new team of reviewers. This was completed in August of 1998. The result was the same as the first bidding process i.e., WHCA was again awarded the contract. Families filed an appeal of this decision which was denied without a hearing. Families appealed this decision to the Superior Court which agreed with the appeal and remanded the case back to DAF directing it to hold a hearing.

On April 18, 2000, a second Appeal Committee convened by the DAF conducted a hearing at which both parties presented evidence. Included in the evidence was a statement by petitioner that it did not want to conduct the services for which it submitted a bid. The Committee found that although Families was considered an “agerieved person” under the regulation which gave it standing to appeal, its subsequent declaration that it no longer wants to provide the domestic violence services encompassed within the RFP, rendered the matter moot and required dismissal of its appeal. The Committee reached this conclusion by considering the petitioner’s statement as “tantamount to a withdrawal of its proposal.” The Committee dismissed the appeal as moot and Families appealed.

In March, 2001, this court ruled on the appeal, finding that the Committee acted ultra vires in dismissing the appeal as moot, and remanding the case to the Committee for a ruling on the merits. The Committee, after consideration of the record as it stood in June, 2000, issued a decision on July 13, 2001, denying Families' appeal. Families now

appeals this latest decision, alleging that the Cornmittee failed to make adequate findings based on the statutory standards of review. It requests the court reverse the Committee’s decision, vacate the contract award and order a re-issue of the RFP.

When the decision of an administrative agency is appealed pursuant to MR. Civ. P. 80C, this court reviews the agency's decision directly for abuse of discretion, errors of law, or findings not supported by the evidence. Centamore v. Dep't of Human Services, 664 A.2d 369, 370 (Me.1995). The reviewing court’s role on appeal is “limited to assuring that the [agency’s] factual findings are supported by competent evidence, that its decision involved no misconception of applicable law and that the application of law to the facts was neither arbitrary nor without rational foundation.” Nancy W. Bayley, Inc. v. Maine Unemployment Security Comm'n, 472 A.2d 1374, 1377 (Me. 1984) (citations omitted). {A] misapplication of the law to the facts will constitute reversible error and if an agency fails to make adequate findings of fact, the court may remand for findings that would permit meaningful judicial review. Id. (internal citations omitted).

Appeals of DHS contract awards are governed by 5 M.R.S.A. § 1825-E and DAF rules, Chap. 120. The guidelines for review by the Appeal Committee are as follows: “The Appeal Committee shall consider all evidence entered into the record and shall look for clear and convincing! evidence that one or more of the standards set forth in Section 3, subsection B, of these rules has been proven by the petitioner.” DAF Rules, chap. 120, § (4)(1). “The evidence presented must specifically address and be limited to one or more of the following: (A) violation of law; (2) irregularities creating

fundamental unfairness; or (3) arbitrary or capricious award.” Id. § (3)(2).

1 The Law Court has defined clear and convincing as “highly probable” not just more probable than not.” Pine Tree Legal Assistance v. Dept. of Human Services, 655 A.2d 1260, 1264 (Me. 1995).

3 The petitioner first argues that the Committee’s decision failed in two respects to address one of the relevant standards of review. Regarding the discrepancies” between the RFP and the rating form, the Committee found no fundamental unfairness, but did not expressly address the issue of whether the discrepancies led to an arbitrary and capricious award. The respondent argues that one conclusion leads to a natural inference of the other. The petitioner makes a similar argument concerning DHS’s decision to not re-bid the contract after the first appeal, instead, re-evaluate the bids. The Committee found this decision did create fundamental unfairness, but again failed to address the arbitrary and capricious standard. The respondent simply argues that the decision was reasonable in light of the circumstances because the RFP itself was not flawed.

It appears from the record that petitioner is correct on both points. The decision of the Committee contains the following reference to the petitioner’s argument: “Families United contends that the contract award process was fundamentally unfair and resulted in an arbitrary and capricious award because (1) the numbering system set forth in the rating form did not consistently follow the numbering in the RFP and (2) a factor-by-factor review of the rating forms shows inexplicable ratings assigned to near identical bidder proposals...” Decision of Appeal Panel after Remand (I), p. 2. It later concludes that it was not convinced that the discrepancies led to fundamental unfairness, but it omits any mention of an arbitrary and capricious award. On the

second point, there is no mention of the arbitrary and capricious argument in the

2 A review of the record indicates only one major discrepancy; section C1b of the RFP asks bidder to explain the scope and volume of various services listed under Community Education/ Community Response while section Clb of the review form asks the raters to score “performance indicators.” decision, but there is evidence in the record the petitioner raised the issue properly. Pet.’s Post-Hearing Brief, p. 17.

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Families United of Washington County, Inc. v. Maine Dep't of Human Servs., Counsel Stack Legal Research, https://law.counselstack.com/opinion/families-united-of-washington-county-inc-v-maine-dept-of-human-servs-mesuperct-2002.