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Law School Case Brief

Valley Constr. Co. v. Hoffman - 417 F. Supp. 926 (S.D. Ga. 1976)


Under the Administrative Procedure Act, an agency ruling is subject to attack only when it is not supported on any rational basis; something more than error is necessary. Courts should not overturn procurement determinations unless the aggrieved party demonstrates that there was no such basis for the agency's decision. The plaintiff bears the heavy burden of proving that a procurement officer's decision was genuinely arbitrary and unreasonable. 


Defendants, the United States Army Corps of Engineers ("Government"), issued invitations to bid for the construction of an Aircraft Corrosion Control Facility at a military base in Georgia. Based upon the limited funds available for additives, only the base bid plus one additive was considered. Intervenor R&D Constructors, Inc. ("R&D") was deemed the low bidder. Plaintiff Valley Construction Company ("Valley") filed a lawsuit in federal district court against the Government and others seeking to enjoin the proposed award of the contract to R&D, contending that the Government acted arbitrarily and capriciously in determining the project funds available and requesting that the court require the Government to include additional additives. Valley would be the low bidder if additional additives were considered. R&D intervened in the action.


Was the Government's award of the contract to R&D arbitrary, unreasonable, or capricious?




The court denied Valley's request for injunctive relief and entered judgment in favor of the Government and R&D. The court concluded that Valley failed to meet the burden of showing that the Government's decisions were arbitrary, unreasonable, or capricious. The sums appropriate by the federal government had to be applied solely to the expenditure's objects; appropriations not used for the specific work designated could not be used for any other purpose. The Government's adherence to the law, no matter how unfair Valley regarded it, was not arbitrary or capricious.

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