Terrebonne Parish School Board v. Group Contractors, LLC

CourtLouisiana Court of Appeal
DecidedJanuary 31, 2025
Docket2023CA1339
StatusUnknown

This text of Terrebonne Parish School Board v. Group Contractors, LLC (Terrebonne Parish School Board v. Group Contractors, LLC) 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
Terrebonne Parish School Board v. Group Contractors, LLC, (La. Ct. App. 2025).

Opinion

COURT OF APPEAL

FIRST CIRCUIT

2023 CA 1339

Judgment Rendered: JAN 3 12025

On Appeal from the Thirty -Second Judicial District Court In and for the Parish of Terrebonne State of Louisiana Docket No. 195980

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Counsel for Plaintiff/Appellee Terrebonne Parish School Board April A. Trahan Harley M. Papa Houma, Louisiana

Edward J. Laperouse, II Counsel for Intervenor/ Appellee Jason A. Bonaventure Edward J. Laperouse Metal Works, Inc. Baton Rouge, Louisiana

Murphy J. Foster, III Counsel for Defendant/ Appellant Jacob E. Roussel Group Contractors, LLC Baton Rouge, Louisiana

BEFORE: McCLENDON, C. 3., HESTER AND MILLER, 33.

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7 McCLENDON, C. 3.

In this public bid dispute, a contractor appeals the trial court's judgment that

declared a contract between it and the school board to be null and void. For the following

reasons, we affirm the judgment of the trial court.

On March 2, 2023, the Terrebonne Parish School Board ( TPSB) filed a Petition for

Declaratory Judgment against Group Contractors, LLC ( Group), asking the trial court to

declare a contract between TPSB and Group as either valid or null and void under

Louisiana law. The contract at issue involves the replacement of the roof at Oaklawn

Middle School in Houma, Louisiana ( the Project) following Hurricane Ida. On December

20, 2022, TPSB submitted a request for bids, and five bids were received by TPSB

between December of 2022 and January of 2023. On January 17, 2023, TPSB opened

the bids for the Project. After disqualifying the first two low bidders due to. non-

responsiveness, TPSB awarded the bid to Group on January 24, 2023. 1 TPSB and Group

signed the written contract for the Project on February 1, 2023. Thereafter, Edward J.

Laperouse Metal Works, Inc. ( Laperouse), the next lowest bidder, sent written objections

to TPSB, asserting that Group failed to follow certain requirements of the bidding

documents.

In response to TPSBs Petition for Declaratory Judgment, Laperouse filed a Petition

for Intervention, Preliminary Injunction, Permanent Injunction, Mandamus Relief and

Declaratory Judgment, naming TPSB and Dr. MayBelle N. Trahan, in her capacity as the

President of TPSB, as defendants. Therein, Laperouse asserted that TPSBs actions of

entering into a contract with Group before post -bid submissions were provided ( or due)

constituted an inappropriate waiver of the requirements of the Public Bid Law and of the

Project documents. Laperouse also alleged that Group's post -bid submission of

documentation regarding a nonauthorized and nonapproved roofing system failed to

meet the requirements of the bidding documents and that TPSBs waiver of the

requirement of an authorized or approved roofing system was a violation of the Public

I The first lowest bidder was declared nonresponsive for failing to use the Louisiana Public Works Uniform Bid Form and Unit Price Form, and the next lowest bidder was declared nonresponsive for not having a Louisiana Building Construction license.

K Bid Law. Laperouse prayed for judgment declaring the contract null and void and

declaring Laperouse to be the lowest responsible and responsive bidder.

Thereafter, Group answered TPSBs petition, requesting that the trial court declare

the contract valid. Following a hearing on Laperouse' s motion for a preliminary injunction,

which was denied, the trial court set the declaratory judgment trial for August 1, 2023.

At the outset of the trial, a Joint Stipulation of Facts Not in Dispute, signed by all the

parties, was introduced into evidence. Attached to the Joint Stipulation were several

exhibits, which included the Bid Package ( with the exception of the plans) and Addendum

No. 1, the Bid Tabulation Sheet, the Contract, TPSBs Special Session Meeting Minutes

for January 24, 2023, Laperouse' s public records request and responses thereto, and

certain other documents, emails, and correspondence.

Jessica Richard, the secretary/ treasurer and a minority owner of Laperouse, was

the only witness to testify at the bench trial. After Ms. Richard' s testimony and following

argument by counsel, the trial court took the matter under advisement. On August 21,

2023, the trial court signed its judgment, as well as separate Reasons for Judgment. The

trial court declared that the contract between TPSB and Group dated February 1, 2023,

was null and void. 2 The trial court also ordered that Laperouse be given an adequate

opportunity to conform to the bidding instructions as the next apparent lowest bidder and

that Laperouse be awarded the contract if it produced all documentation in the requisite

period of time as required in the bidding instructions and under the Public Bid Law.3

Group appealed and assigned the following as error:

1. The trial court erred in ruling that provisions of the bidding documents regarding

the furnishing of a post -bid submittal " prior to award of the contract" contained a

legally valid bid requirement that could serve as a basis for rendering null and void

the construction contract entered into between TPSB and Group; and

2. The trial court erred in ruling that any deadline for the post -bid submittal at issue

was applicable to Group as the third lowest bidder.

2 We note that although the trial court's judgment states that the contract was dated February 6, 2023, the contract was dated February 1, 2023. 3 In its appellate brief, Laperouse states that it complied with the bid instruction requirements and that on September 20, 2023, the contract for the Project was awarded by TPSB to Laperouse, who began working on the Project.

3 Louisiana' s Public Bid Law is set forth in LSA- R. S. 38: 2211, etseq. The Public Bid

Law is a prohibitory law founded on public policy. Barriere Construction Co.,, L. L. C.

v. Parish of Tangipahoa, 2018- 0279 ( La. App. 1 Cir. 9/ 24/ 18), 259 So. 3d 458, 461.

Louisiana Revised Statutes 38: 2212( A)( 1)( a) mandates that all public work exceeding the

defined contract limit as set forth in LSA- R. S. 38: 2212( C)( 1) be advertised and let by

contract to the " lowest responsible and responsive bidder."

The Public Bid Law serves the dual purposes of eliminating fraud and favoritism

and securing free and unrestricted competition among bidders, thereby avoiding undue

or excessive costs. Lathan v. City of Gonzales through Arceneaux, 2021- 0825

La. App. 1 Cir. 2/ 25/ 22), 340 So. 3d 1146, 1149. A political entity has no authority to

take any action that is inconsistent with Louisiana' s Public Bid Law. Hamp' s

Construction, L. L. C. v. City of New Orleans, 2005- 0489 ( La. 2/ 22/ 06), 924 So. 2d

104, 107. The provisions and requirements of the Public Bid Law, as well as those stated

in the bidding documents, shall not be considered as informalities and shall not be waived

by any public entity. 5 LSA- R. S. 38: 2212( B)( 1). No public work may be done except as

provided in the Public Bid Law, and any contravention of its provisions renders the

resulting contract null and void. LSA- R. S. 38: 2220; Barriere, 259 So. 3d at 461.

In this sense, the Public Bid Law severely curtails the discretion of the public entity,

thereby ensuring a level playing field for all bidders and a fair and equitable means by

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Related

Barriere Const. v. Terrebonne Consol. Gvt.
754 So. 2d 1123 (Louisiana Court of Appeal, 2000)
Broadmoor, LLC v. ERNEST N. MORIAL EXHIBITION
867 So. 2d 651 (Supreme Court of Louisiana, 2004)
HAMP'S CONST. v. City of New Orleans
924 So. 2d 104 (Supreme Court of Louisiana, 2006)
Phylway Construction, LLC v. Terrebonne Parish Consolidated Government
153 So. 3d 516 (Louisiana Court of Appeal, 2014)
Barriere Constr. Co. v. Parish of Tangipahoa
259 So. 3d 458 (Louisiana Court of Appeal, 2018)

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Terrebonne Parish School Board v. Group Contractors, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/terrebonne-parish-school-board-v-group-contractors-llc-lactapp-2025.