Rubbermaid Applied Products, Inc. v. City of Richmond

36 Va. Cir. 566, 1982 Va. Cir. LEXIS 135
CourtRichmond County Circuit Court
DecidedNovember 17, 1982
DocketCase No. G 8270-2
StatusPublished

This text of 36 Va. Cir. 566 (Rubbermaid Applied Products, Inc. v. City of Richmond) is published on Counsel Stack Legal Research, covering Richmond County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rubbermaid Applied Products, Inc. v. City of Richmond, 36 Va. Cir. 566, 1982 Va. Cir. LEXIS 135 (Va. Super. Ct. 1982).

Opinion

By Judge Marvin F. Cole

On September 16, 1982, the plaintiff, Rubbermaid Applied Products, Inc., filed its First Amended Bill of Complaint, alleging essentially three things: (1) that Rubbermaid was the lowest responsible bidder on the refuse container carts because Zarn failed to meet, and specifically excepted to, Specification 3.2; (2) that Rubbermaid was the lowest responsible bidder because when requested to submit a sample for testing, Zarn improperly submitted a “prototype” sample and did not timely submit a production sample as requested; (3) that Rubbermaid was the lowest responsible bidder because Zarn violated the Department of General Services “no contact” policy precluding contact between bidders and the Department in the interim between the bid opening and the bid award. By virtue of these three violations, Rubbermaid asked the court to enjoin the City of Richmond from awarding the contract to Zam and to award the contract to Rubbermaid as the lowest responsible bidder. Or in the alternative, Rubbermaid asks that the City be required to resolicit the bid for the refuse container carts. At the trial, counsel abandoned the first request and asked the court to consider only the resolicitation of the bids.

The court shall consider each of the above three points in the order stated.

[567]*567(1) Zarn failed to meet and specifically excepted to Specification 3.2

Paragraph 3.2 in the specifications in the Request for Bids sets forth the following:

Metal Hardware: All metal parts, interior and exterior, are to be stainless steel or to be protected against corrosion through the use of paint, zinc plating, or other appropriate coating with a minimum thickness of not less than 0.001 inch.

Zarn, in its bid submitted to the Department of General Services on June 1,1982, stated the following:

The following minor exceptions to your specifications should be noted:
1. Not applicable.
2. Not applicable.
3. Item 3.2 — The minimum thickness of coatings specified at 0.001 inch can be supplied on all hardware except small items such as nuts and bolts. These items cannot be assembled if they are coated this heavily. Maximum allowable plating and coatings are included on these minor parts on the Zarn Roll-A-Waste carts.

We can therefore see from the Zarn bid that they have not complied with paragraph 3.2 of the specifications because Zarn admits that small items such as nuts and bolts could not be assembled by them having a minimum thickness of 0.001 inch. The testimony of Walter J. Sperko, a metallurgical engineer who tested the Zarn nuts and bolts, was to the effect that die Zarn nuts and bolts were coated with a zinc coating; that one of the primary purposes for using a zinc coating was that it has a uniform rate of corrosion in a given environmental situation and that this enables engineers to approximate the life expectancy of the zinc coating; that the life expectancy of the zinc coating is directly proportional to the thickness of the coating; that in his opinion the life expectancy of the zinc coating in ti» Richmond environment for the Zarn nuts and bolts would be approximately five years; that he performed A.S.T.M. standard tests to determine the thickness of the zinc coating on the Zarn nuts and bolts and that die values ranged from typically about 1.5 mils in coating thickness. One very large bolt had a coating of approximately nine-tenths of a mil. This testimony reflects that even the nuts and bolts of Zarn exceed the specification [568]*568of a thickness of 0.001 inch and that only one very large bolt had a coating of 0.0009 inch.

Under § 5-1.4 of the City Charter, the Department of General Services is required to make certain purchases, including the purchase involved in this action, by competitive bidding and to award the contract to the “lowest or best responsible bidder.” Section 14-6 of the Code of the City of Richmond requires the Department to award such contracts to the “lowest responsible bidder” and set out certain criteria for determining the “lowest responsible bidder.”

The Supreme Court of Virginia has discussed similar language in the case of Taylor v. Arlington County Board, 189 Va. 472, and in that case the court cited with approval the following statements, which are applicable to this case:

It is next urged by the appellants that the County Board had no right to evaluate the bids, first, because no notice of such action was given, and second, the method used was unwarranted. We think neither of these contentions is sound.

In the case at bar, the request for bids stated that the purchase would be made only “if and when ordered.” The City did not agree to purchase anything. The request for bids also indicated that the bidder could be required to produce sample containers, and further stated that “as bids of this nature require more time for evaluation than do the average, if the figure inserted here is less than 45, bid may not be considered.” Therefore, it is seen that the bidders had to have known that the City would carefully evaluate each bid.

The “lowest” bid may be determined by monetary standards with the dollars as the unit, but this is not so in determining the “best” bid, or the “responsible” bid; that question involves a number of other factors and elements . A decision as to the lowest and best bidder for a supply contract involves a determination of the least expenditure of public funds and a consideration of the quality of the goods proposed to be furnished and the other factors and elements adverted to above.
Clearly, among the factors so involved are the experience of the bidder in that field, the quality of his previous work and the cost, not alone of constructing what he proposes to build, but of operating it after it is built. All else being equal, it is the duty of [569]*569the public authorities to accept the bid involving the least expenditure of public funds.
When the decision of the authorities is based upon a fair and honest exercise of their discretion, it will not be interfered with by tiie courts, even if erroneous. Courts do not in such cases substitute their judgment for the judgment of the body to which the decision is confided. Interference by the courts is limited to cases in which the public body has proceeded illegally or acted arbitrarily or fraudulently.
Generally, before a variation from the specifications will be deemed to destroy the competitive character of a bid for a public contract, the variation must be substantial, that is, if must affect the amount of the bid. It is sufficient if the bid conforms substantially to the advertisement.

It is my opinion in this case that the Zarn bid does conform substantially to the specifications of the bid request. It should be remembered that we are not concerned here with any piece of equipment that is highly technical and complicated. It is only a plastic container with a lid upon it and with some metal components for holding it together and to provide for dumping. The allegation of the plaintiff is that the nuts and bolts used by Zarn do not meet the specifications because the coating to prevent corrosion is not 0.001 inch.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Taylor v. County Board of Arlington County
53 S.E.2d 34 (Supreme Court of Virginia, 1949)

Cite This Page — Counsel Stack

Bluebook (online)
36 Va. Cir. 566, 1982 Va. Cir. LEXIS 135, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rubbermaid-applied-products-inc-v-city-of-richmond-vaccrichmondcty-1982.