Montgomery Park v. Dept. of Gen. Services

290 A.3d 586, 482 Md. 706
CourtCourt of Appeals of Maryland
DecidedFebruary 24, 2023
Docket12/22
StatusPublished
Cited by6 cases

This text of 290 A.3d 586 (Montgomery Park v. Dept. of Gen. Services) is published on Counsel Stack Legal Research, covering Court of Appeals of Maryland primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Montgomery Park v. Dept. of Gen. Services, 290 A.3d 586, 482 Md. 706 (Md. 2023).

Opinion

Montgomery Park, LLC v. Maryland Department of General Services, Nos. 12 & 13, September Term, 2022. Opinion by Eaves, J.

STATE FINANCE AND PROCUREMENT – MARYLAND STATE BOARD OF CONTRACT APPEALS – LEGAL STANDARD OF REVIEW FOR CANCELLATION OF INTENDED PROCUREMENT AWARDS

The Supreme Court of Maryland held that in a bid protest filed under the State Finance and Procurement Article of the Maryland Code (“SF”), Title 15, Subtitle 2, the standard of review that the Maryland State Board of Contract Appeals (“Board”) must apply to a procurement officer’s decision to cancel a request for proposal (“RFP”) is the arbitrary or capricious standard.

In this case, the Procurement Officer for the Department of General Services (“DGS”) issued an RFP seeking bids for a new lease for the Maryland Insurance Administration (“MIA”) headquarters. The Procurement Officer thereafter cancelled the RFP after notifying Montgomery Park, LLC (“Montgomery Park”) that it was the intended awardee of the bid for new office space, but prior to approval of the bid by the Board of Public Works. Montgomery Park filed a bid protest with the Board, which reversed the Procurement Officer’s decision. The Supreme Court held that the Board erred in concluding that the Procurement Officer’s decision was arbitrary and capricious.

STATE FINANCE AND PROCUREMENT – BID PROTEST – STANDING

To file a bid protest under State procurement law, the protestor must be an interested party. An interested party is defined as an “actual or prospective bidder, offeror, or contractor that may be aggrieved by the solicitation or award of a contract, or by the protest.” Md. Code Regs. 21.10.02.01B(1).

The Supreme Court held that Montgomery Park lacked standing to protest the sole source renewal of the existing lease between MIA and St. Paul Place. The Court held that the RFP for office space and the subsequent renewal of the existing lease were two factually and legally distinct events that must be considered separately. The Court determined that, once the Procurement Officer cancelled the RFP, Montgomery Park was “no longer an ‘actual or prospective bidder [or] offeror[.]” With the RFP no longer in effect, under SF § 13- 105(g), the Procurement Officer was entitled to proceed with the renewal of the existing lease as a sole-source contract renewal, without soliciting other offers. Because Montgomery Park had no interest in the existing lease and was never in line for an award of a lease renewal under the sole-source renewal provisions of State law, the Court held that it lacked standing to challenge the renewal lease. Circuit Court for Baltimore City Case Nos. 24C20000887 & 24C20001565 Argued: October 3, 2022 IN THE SUPREME COURT

OF MARYLAND*

Nos. 12 & 13

September Term, 2022

MONTGOMERY PARK, LLC

v.

MARYLAND DEPARTMENT OF GENERAL SERVICES

Watts, Hotten, Booth, Biran, Gould, Eaves, Harrell, Glenn T., Jr. (Senior Justice, Specially Assigned)

JJ.

Opinion by Eaves, J.

Filed: February 24, 2023

* At the November 8, 2022, general election, the voters of Maryland ratified a constitutional Pursuant to the Maryland Uniform Electronic Legal Materials Act (§§ 10-1601 et seq. of the State Government Article) this amendment changing the name of the Court of document is authentic. Appeals to the Supreme Court of Maryland. The 2023-02-24 14:17-05:00 name change took effect on December 14, 2022.

Gregory Hilton, Clerk The dispute in this case arises from two decisions of the Maryland State Board of

Contract Appeals (“the Board”) that sustained two bid protests filed by Montgomery Park,

LLC (“Montgomery Park”). In 2017, the Maryland Department of General Services

(“DGS”), on behalf of the Maryland Insurance Administration (“MIA”), issued a Request

for Proposal (“RFP”) for office space. Although Montgomery Park was initially named

the intended awardee, DGS, through its Procurement Officer, later cancelled the RFP

before the award was presented to the Board of Public Works for approval. After

cancelling the RFP for new office space, the Procurement Officer negotiated a renewal of

MIA’s existing lease at 200 St. Paul Place in Baltimore City.

In response to DGS’s actions, Montgomery Park filed two separate bid protests—

one relating to the Procurement Officer’s decision to cancel the RFP, and a second one

relating to the renewal of the existing lease between MIA and St. Paul Place (hereinafter

referred to as “St. Paul Plaza” or “leased premise” as appropriate to the context). The

Procurement Officer denied both bid protests. The Procurement Officer determined that

the cancellation of the RFP complied with the applicable provisions of the State Finance

and Procurement Article of the Maryland Code and the Code of Maryland Regulations

(“COMAR”). With respect to the second bid protest, the Procurement Officer determined

that Montgomery Park did not have standing to challenge the lease renewal, but even if it

did, the lease renewal was negotiated pursuant to the provisions of State law that permit

the renewal of an existing lease without soliciting other offers. Thereafter, Montgomery

Park appealed the Procurement Officer’s decisions to the Board, which overturned the

Procurement Officer’s decisions. The Board determined that the Procurement Officer’s cancellation of the RFP and subsequent lease renewal violated Maryland procurement law.

In a separate opinion, the Board concluded that Montgomery Park had standing to

challenge the Procurement Officer’s renewal of MIA’s existing lease. Turning to the

merits, the Board ruled that the Procurement Officer violated the procurement law by

failing to document separately her reasons for determining that it was in the State’s best

interest to renew the lease with St. Paul Plaza.

DGS appealed the Board’s two decisions to the Circuit Court for Baltimore City,

which reversed the Board. Montgomery Park appealed the circuit court’s decisions to the

Appellate Court of Maryland (at the time named the Court of Special Appeals of

Maryland).1 The Appellate Court affirmed the circuit court’s rulings in a reported opinion.2

Montgomery Park petitioned this Court for a writ of certiorari, which this Court granted

on June 3, 2022.3 Montgomery Park presents the following questions for our review, which

we have rephrased as follows:4

1 At the November 8, 2022, general election, the voters of Maryland ratified a constitutional amendment changing the name of the Court of Special Appeals of Maryland to the Appellate Court of Maryland. The name change took effect on December 14, 2022. 2 Montgomery Park, LLC v. Maryland Dep’t of Gen. Servs., 254 Md. App. 73 (2022). 3 Montgomery Park, LLC v. Maryland Dep’t of Gen. Servs., 479 Md. 64 (2022). 4 The questions presented in the petition for a writ of certiorari were:

1. Is it arbitrary or capricious for a procurement officer to cancel the proposed award of a procurement contract without making independent “written findings” required by Maryland law to support that decision, and instead relying on someone else’s findings that were not supported by the administrative record? 2 1. Did the Board err in determining that the Procurement Officer’s decision to cancel the RFP for an office lease in connection with the relocation of MIA’s headquarters was arbitrary and capricious?

2. Did the Board err in determining that Montgomery Park, as the intended awardee of the RFP, had standing to challenge the renewal of MIA’s existing lease after the RFP was cancelled?

For the following reasons, this Court answers “yes” to both questions and shall affirm

the judgment of the Appellate Court of Maryland.

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Cite This Page — Counsel Stack

Bluebook (online)
290 A.3d 586, 482 Md. 706, Counsel Stack Legal Research, https://law.counselstack.com/opinion/montgomery-park-v-dept-of-gen-services-md-2023.