River/Road Construction, Inc. v. City of New Orleans

667 So. 2d 1166, 95 La.App. 4 Cir. 1782, 1996 La. App. LEXIS 106, 1996 WL 11848
CourtLouisiana Court of Appeal
DecidedJanuary 11, 1996
DocketNo. 95-C-1782
StatusPublished
Cited by1 cases

This text of 667 So. 2d 1166 (River/Road Construction, Inc. v. City of New Orleans) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
River/Road Construction, Inc. v. City of New Orleans, 667 So. 2d 1166, 95 La.App. 4 Cir. 1782, 1996 La. App. LEXIS 106, 1996 WL 11848 (La. Ct. App. 1996).

Opinions

JiCIACCIO, Judge.

WRIT GRANTED

We granted certiorari in this case to consider the propriety of the trial court’s denial of relator’s petition for preliminary injunction. For the reasons stated more fully herein, we reverse the judgment of the trial court and remand this ease to the trial court with instructions.

STATEMENT OF THE FACTS

On April 4, 1995, the City of New Orleans issued a proposal which invited sealed, competitive bids from parties interested in contracting for the collection, shredding and disposal of approximately 700,000 waste tires located in Orleans Parish. Bidders were asked to bid a single unit price per tire to cover all costs to shred each tire and haul and dispose of the shreds.

Pursuant to this invitation for bids, over 20 companies attended a mandatory pre-bid conference held on April 25,1995. However, only two companies actually submitted bids for the project: River Road Construction, Inc., relator herein, and Merrick Construction, Inc. At the bid opening on May 18, 1995, River Road submitted the lowest bid of $1.0989 per tire and Merrick submitted a higher bid of $1.38 per tire. On its face, the River Road bid was twenty percent lower than the Merrick bid. Relator alleged that the price differential was approximately $200,000.00.

Following the submission of bids, the City notified River Road by letter dated July 18, 1995 that it proposed to disqualify River Road’s bid because the 1 2City had received a bid from a higher ranking bidder. River Road requested a hearing to protest its proposed disqualification, and this hearing was held on July 26,1995. On July 27, 1995, the [1168]*1168City Attorney’s office found River Road’s protest to be without merit and recommended the contract be awarded to Merrick Construction, Inc.

On July 28, 1995, River Road filed a Petition for Preliminary and Permanent Injunction and for Writ of Mandamus seeking to enjoin the City from awarding the contract to any other bidder other than River Road. In its petition, River Road contended that the disqualification of their bid was in violation of the Public Bid Law, LSA-R.S. 38:2212. River Road also filed a Motion for Temporary Restraining Order on this date which was denied by the trial court. The matter was set for hearing on the preliminary injunction on August 7, 1995. On July 31, 1995, the trial court issued an order that the application for the preliminary injunction was to be heard upon the verified pleadings and supporting affidavits alone. No objection was made by the parties to this procedure, and there was no request for an evidentiary hearing.

Accordingly, the matter was submitted to the court for consideration on the basis of pleadings, affidavits and exhibits. On August 7, 1995 the trial court rendered judgment with written reasons denying River Road’s petition for preliminary injunction.

River Road now seeks supervisory review from this Court, arguing that the disqualification of its bid by the City constitutes a violation of the Public Bid Law, more particularly LSA-R.S. 38:2212.A.(1)(a), which requires that all contracts be awarded to the “lowest responsible bidder.” Plaintiff seeks to enjoin the disqualification of its bid and alternatively to annul the contract to Merrick if it has been awarded. River Road also seeks a writ of mandamus requiring the City to award the contract to River Road.

J¿DISCUSSION

The combined provisions of the City Public Bid Law found in Section 6-307(5) of the Home Rule Charter for the City of New Orleans and the State Public Bid Law in LSA-R.S. 38:2211, et seq., require that contracts for any services, other than “professional” services, be let out by public bid. The Public Bid Law requires that the contract for public work be awarded to the “lowest responsible bidder who has bid according to the contract, plans and specifications, as advertised, ...” LSA-R.S. 38:2212(A)(1)(a).

River Road argues that their bid constitutes the lowest responsible bid, and the City is therefore required to award the contract to River Road. They argue that their bid complies with the contract and specifications, and that River Road has proven experience and capabilities sufficient to perform the work.

The City’s decision to disqualify River Road’s bid was based on a section contained in the general specifications of the bid proposal in which the City establishes a ranking system as follows:

Because the City desires to promote the recycling of resources as opposed to land disposal, the City will give the highest priority to the lowest responsible bid that conforms to the following order of processing/disposal techniques:
Priority 1. Processor/Recyeler
Priority 2. Processor/Monofill (Temporary Storage for Recycling)
Priority 3. Processor/Beneficial Reuse
Priority 4. Processor/Landfill Disposal

The City found that River Road’s bid should be ranked as a Priority 4 because River Road proposed to dispose of the tire shreds at a landfill which was authorized by the City’s bid specifications. The City ranked Merrick as a Priority 1 because Merrick proposed to dispose of the tire shreds at a monofill. The City thus concluded that regardless of the lower monetary bid submitted by |4River Road, Merrick should be awarded the contract because of its higher priority ranking.

In response to this determination, River Road contends that the City’s use of this priority system is not authorized by the legislative statute or the departmental regulations and is therefore impermissible. We agree.

LEGISLATIVE HISTORY

The City contends that this priority ranking system incorporated in its bid proposal [1169]*1169was mandated by the legislature in the statute governing the disposal of waste tires, LSA-R.S. 30:2418. This statute is incorporated in the Solid Waste Recycling and Reduction Law, LSA-R.S. 30:2411-2423. R.S. 2418, effective September 1, 1989, provides for the establishment of waste tire collection centers and renders it unlawful for any person to dispose of tires unless they are disposed of for processing at a permitted solid waste disposal facility. Section C of this statute provides that waste tires which have been prepared for disposal by cutting, separating, shredding or other means in accordance with the rules or standards of the department may be disposed of in a landfill.

Section H of that statute provides as follows:

H. On or before January 1, 1993 the secretary shall promulgate regulations and guidelines for the administration and enforcement of the waste tire program provided for in this Chapter which shall be subject to legislative review and approval by the Senate Committee on Environmental Quality and the House Committee on Natural Resources. The regulations and guidelines shall provide for but not be limited to:
(1) Establishing standards, requirements, and permitting procedures for waste tire transporters, collection sites, and processors. Requirements shall include proof of liability insurance in a sufficient amount and other evidence of financial responsibility as determined by the secretary.

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Bluebook (online)
667 So. 2d 1166, 95 La.App. 4 Cir. 1782, 1996 La. App. LEXIS 106, 1996 WL 11848, Counsel Stack Legal Research, https://law.counselstack.com/opinion/riverroad-construction-inc-v-city-of-new-orleans-lactapp-1996.