Seal & Co. v. Washington Metropolitan Area Transit Authority

768 F. Supp. 1150, 1991 U.S. Dist. LEXIS 9501, 1991 WL 125141
CourtDistrict Court, E.D. Virginia
DecidedJuly 8, 1991
DocketCiv. A. 91-682-A
StatusPublished
Cited by18 cases

This text of 768 F. Supp. 1150 (Seal & Co. v. Washington Metropolitan Area Transit Authority) is published on Counsel Stack Legal Research, covering District Court, E.D. Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Seal & Co. v. Washington Metropolitan Area Transit Authority, 768 F. Supp. 1150, 1991 U.S. Dist. LEXIS 9501, 1991 WL 125141 (E.D. Va. 1991).

Opinion

MEMORANDUM OPINION

ELLIS, District Judge.

Introduction

This is a disappointed bidder’s challenge to a contract award made by the Washington Metropolitan Area Transit Authority (“WMATA”). It raises the infrequently litigated issue of whether an unsuccessful bidder has standing to challenge the contract award of an interstate agency created by interstate compact. Plaintiff, the unsuccessful bidder, charges that WMATA’s award was unlawful and seeks cancellation of the award together with issuance of a permanent injunction enjoining WMATA from awarding the contract to any party other than plaintiff.

Plaintiff originally moved for a preliminary injunction. Pursuant to Rule 65(a)(2), Fed.R.Civ.P., the hearing on the preliminary injunction was consolidated with the hearing on the merits. At the consolidated *1152 hearing, the parties argued the issues orally and submitted the ease on the basis of stipulated facts, briefs and oral arguments. On the basis of the record as a whole, the Court concludes that plaintiff has standing to challenge WMATA’s contract award, but that plaintiffs claims lack merit. Accordingly, plaintiff is not entitled to the relief sought.

Facts 1

Plaintiff, Seal and Company, Inc., is a District of Columbia corporation having its principal place of business in Chantilly, Virginia. It is engaged in the electrical contracting business and has successfully bid on and performed contract work for WMA-TA since 1972. Defendant WMATA is an interstate agency created by the Washington Metropolitan Area Transit Authority Compact (“the Compact”) executed by Virginia, Maryland and the District of Columbia and approved by Congress 2 in accordance with the U.S. Const. art. I, § 10, cl. 3. WMATA, under the Compact, is charged with operating the Metro system serving the Washington metropolitan area. Defendant Dynatran is a corporation having its principal place of business in Sterling, Virginia. It is the successful bidder for the challenged contract award.

On February 19, 1991, WMATA issued Invitation for Bids No. IFB-C-882 (“the IFB”) requesting bids on the construction of the communications system for Metro’s Green Line between Fort Totten and Greenbelt, Maryland. The IFB contained a “Buy American Certificate” which bidders were expected to execute, along with numerous other certificates. 3 WMATA received numerous bids. Plaintiff was the low bidder, but had not executed the Buy American Certificate contained in its bid. Dynatran was the second lowest bidder. No allegations have been made suggesting that Dynatran’s bid failed in any way to conform to the IFB. Upon opening the bids and noting plaintiff’s unexecuted Buy American Certificate, WMATA contacted plaintiff’s representatives, who in turn immediately forwarded an executed Buy American Certificate. That same day, however, WMATA verbally advised plaintiff that it regarded plaintiff’s bid as nonre-sponsive because, as initially submitted, the bid did not include an executed Buy American Certificate. On April 18th and 19th, plaintiff sent letters to WMATA protesting the determination that its bid was nonre-sponsive. As the next lowest bidder and beneficiary of this determination, Dynatran protested any award to plaintiff. By letter dated May 6, 1991, WMATA’s contracting officer issued his final decision denying plaintiff’s protest and confirming the determination that plaintiff’s bid was nonre-sponsive. Plaintiff then initiated this action by filing its complaint on May 16,1991.

Analysis

This Court has subject matter jurisdiction pursuant to Section 81 of the Compact. 4 Plaintiff contends that WMATA has acted arbitrarily and in violation of its own procurement regulations and existing law by failing to award the disputed contract to plaintiff, as the lowest responsible bidder. In particular, plaintiff contends that completing the Buy American Certificate is not a condition of responsiveness. Alternatively, plaintiff contends that even if the Buy American Certificate is a condition of re *1153 sponsiveness, its requirements are incorporated into the specifications of the IFB and hence, by signing the IFB, plaintiff bound itself to purchase only domestic supplies. Finally, plaintiff argues that WMATA may not penalize it for failing to sign the Buy American Certificate since WMATA did not explicitly give notice in the IFB that signing the Certificate was a condition of responsiveness and because the Certificate was ambiguously worded. In opposition, WMATA maintains that disappointed bidders such as plaintiff lack standing to challenge WMATA’s contract awards. Alternatively, WMATA maintains that its rejection of plaintiff’s bid as nonresponsive was reasonable and in accordance with WMA-TA regulations and relevant procurement decisions of the Comptroller General. Since standing is a threshold matter, it is addressed first followed by the merits issues.

I.

The standing issue has two parts, one concerning the existence of a “private cause of action,” and the second relating to “standing” or “injury.” More specifically, the Court must first determine whether Congress in enacting the Compact intended to create “a cause of action” for private parties aggrieved by WMATA’s alleged failure to follow the procurement procedures mandated by the Compact. “The question whether a statute creates a cause of action, either expressly or by implication, is basically a matter of statutory construction.” Transamerica Mortgage Advisors, Inc. v. Lewis, 444 U.S. 11, 15, 100 5.Ct. 242, 245, 62 L.Ed.2d 146 (1979). “[W]hat must ultimately be determined is whether Congress intended to create the private remedy asserted_” Id. at 15-16, 100 S.Ct. at 245. This intent may appear explicitly in the language of a statute or its legislative history, or “[s]uch an intent may appear implicitly in the language or structure of the statute, or in the circumstances of its enactment.” Id. at 18, 100 S.Ct. at 246; see Thompson v. Thompson, 484 U.S. 174, 108 S.Ct. 513, 516, 98 L.Ed.2d 512 (1988); Touche Ross & Co. v. Redington, 442 U.S. 560, 99 S.Ct. 2479, 61 L.Ed.2d 82 (1979). If the Court finds that Congress intended to create a private cause of action, it must then determine whether the plaintiff alleges an injury of the kind intended to be protected by the Compact, i.e., whether plaintiff’s alleged injury falls within the “zone of interests” 5 Congress intended to protect.

When the action of a federal agency is at issue, the two part analysis just described is somewhat simplified.

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768 F. Supp. 1150, 1991 U.S. Dist. LEXIS 9501, 1991 WL 125141, Counsel Stack Legal Research, https://law.counselstack.com/opinion/seal-co-v-washington-metropolitan-area-transit-authority-vaed-1991.