Sheet Metal Employers' Ass'n v. Giordano

188 N.E.2d 329, 91 Ohio Law. Abs. 281, 23 Ohio Op. 2d 25, 1963 Ohio Misc. LEXIS 257
CourtCuyahoga County Common Pleas Court
DecidedJanuary 19, 1963
DocketNo. 772745
StatusPublished

This text of 188 N.E.2d 329 (Sheet Metal Employers' Ass'n v. Giordano) is published on Counsel Stack Legal Research, covering Cuyahoga County Common Pleas Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sheet Metal Employers' Ass'n v. Giordano, 188 N.E.2d 329, 91 Ohio Law. Abs. 281, 23 Ohio Op. 2d 25, 1963 Ohio Misc. LEXIS 257 (Ohio Super. Ct. 1963).

Opinion

Hoddinott, J.

Plaintiff Sheet Metal Employers Association, Inc., is a trade association of sheet metal contractors in the Cleveland metropolitan area extending over four counties. One of its members is Plaintiff Franck & Fric, Inc.

This suit involves a bid depository, something new in the construction industry. Similar organizations have operated in several other cities for a few years.

In the construction of a public building, the governmental authority usually lets a contract for the heating, ventilating and aid conditioning to what is called a mechanical contractor. The sheet metal work is then sublet to a sheet metal contractor whose firm bid was in the hands of the mechanical contractor at the time it made its bid.

A troublesome problem of the sheet metal industry is the-practice of job shopping. Many hours are invested by the-engineers and management of a sheet metal contractor in pre[283]*283paring a bid for submission to the mechanical contractor. The latter may then proceed to play one bidder against another, getting each in turn to shave its bid as much as it will. Estimated profit is drastically reduced and financial loss threatens. There is little satisfaction in such a contract. The temptation to do inferior work and to cheat is strong.

To combat this practice, the two interested trade associations, Plaintiff Sheet Metal Employers Association and the Mechanical Contractors Association of Cleveland set up a bid depository in March, 1962. Rules and regulations were adopted and a bid depository committee, consisting of two members from each association, went into operation. Announcements of the bid depository and copies of its rules were sent to sheet metal and mechanical contractors in the area.

The procedure is for a mechanical contractor to notify the Central National Bank of Cleveland o.r Plaintiff Sheet Metal Employers Association of its intention to accept bids from the depository on a certain job. Sheet metal contractors then may submit to the bank’s trust officer sealed bids addressed to named mechanical contractors. These are accompanied by duplicates, also sealed, whose function will be explained later. All sheet metal bids must be in by noon of the day before bids on the prime contract are to be opened by the governmental authority. The mechanical contractor may take all the sealed bids in the depository addressed to him, or some of them, or none of them.

After the prime contract bids are opened and read by the governmental authority on the next day, the duplicates of the bids accepted from the depository by the successful mechanical contractor are opened, and the lowest bid is certified by the executive secretary of the Sheet Metal Employers Association. Information on the low bid is made available to the other bidders in the depository.

If a mechanical contractor takes any sealed bids from the depository, it must accept the lowest of them. A sheet metal contractor who uses the depository cannot make bids outside, nor change his bids after the depository deadline. Otherwise, use of the depository is not compulsory.

Defendant Louis Giordano does business as Forest Hills Plumbing & Heating Company. In his employ is Defendant [284]*284George Regan, an engineer, who is primarily responsible for preparing job bids.

In tbe summer of 1962, Giordano wished to bid as mechanical contractor on the multi-million dollar Mayfield Heights high school job. Since it was to be the first air-conditioned school in this vicinity, the heating, ventilating and air conditioning contract would be substantial. Giordano and Regan knew of the bid depository, had a copy of its rules in their office, but had not used its services before. The depository was notified that Giordano would accept sheet metal bids through it.

At noon on July 30, 1962, Regan took delivery from the depository of six sealed bids addressed to Giordano. On behalf of his employer, he signed a receipt containing these word:

Pursuant to the provisions of the Bid Depository Rules and Regulations of the Sheet Metal Employers Association, we hereby acknowledge receipt of bids from Sheet Metal Contractors as indicated below: . . . .

Upon opening the bids, Regan found that the bid of A. A. Samuels Sheet Metal was lowest and that of Plaintiff Franck & Fric next, about $4400 higher. All bids were accompanied by bid bonds guaranteeing that the bidder would execute a contract if his bid were accepted. Samuels’ bond, however, was for only 5% of the amount of the bid, whereas Franck & Fric and the other bidders had given 100% bonds.

Giordano’s bid was due at the school board at 1:00 P. M., the next day. Regan made several telephone calls to the sheet metal bidders concerning details. During one, he asked R. A. Schuenaman, an officer of Plaintiff Franck & Fric, if Samuels’ bid bond in the amount of only 5% disqualified that bid. Upon Schuenaman’s saying he believed so, Regan asked him to get a ruling for him. Regan testified he called the depository bank’s trust officer who suggested he call Plaintiff Sheet Metal Employers Association’s executive secretary. That man was out of town. Regan testified he also tried to call the two sheet metal members of the bid depository committee, Hodous and Mannen, but they were not available. The next morning, around 10.30 A. M., Schuenaman called Regan and said he could not obtain a ruling on the point. Giordano then used Samuels’ bid in computing his own mechanical contractor’s bid, which was [285]*285submitted before 1:00 P. M., that day. G-iordano was low bidder and eventually was awarded tbe contract.

Later, the same day, the bid depository committee during telephone conversations among themselves agreed upon the ruling that the Samuels’ bid was not qualified because of the bid bond. Plaintiff Franck & Fric’s bid was declared to be the lowest qualified bid and Giordano was so notified. Franck & Fric later tendered performance, and Giordano refused to enter into a contract. He announced his intention to accept the Samuels’ bid, the lowest one, but did not do so when threatened with suit.

There was evidence that bid bonds, guaranteeing a successful bidder will execute a contract, have not been given customarily by sheet metal contractors. On the other hand, such bonds are required by law to accompany mechanical contractors’ bids to governmental authorities. When the latter bid has been accepted, the successful mechanical contractor must give a performance bond guaranteeing its work, and it in turn usually requires performance bonds from the subcontractors to whom it awards business.

The bid bond of Samuels was in the amount of 5% rather than 100% through mere accident. He went to his bonding company and ordered the bond. The request was a novel one, not fully understood by the company, one of the best established in the field. Its agent consulted the Dodge Corp. construction reports which disclosed that a 5% bid bond was required by the Mayfield Heights School Board from the mechanical contractors bidding on this particular job. The company then executed a 5% bond for Samuels, and he attached it to his bid placed in the depository.

Bid bonds are issued almost gratuitously. Because Samuels’ bonding company is willing to sell performance bonds to him, it will issue, for a charge of $5.00 per year, as many bid bonds as he requires. The understanding is that the company will get the performance bond business when Samuels is the successful bidder.

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Bluebook (online)
188 N.E.2d 329, 91 Ohio Law. Abs. 281, 23 Ohio Op. 2d 25, 1963 Ohio Misc. LEXIS 257, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sheet-metal-employers-assn-v-giordano-ohctcomplcuyaho-1963.