HomeMy WebLinkAbout16 - Fire Station No. 6 Apparatus Bay Replacement - CorrespondenceWATT TIEDER
WATT, TIEDER, HUFFAR & FITZGERALD, L.L.P.
June 9, 2017
VIA EMAIL AND FEDEX
OVERNIGHT DELIVERY
Mr. Fong Tse
City of Newport Beach
100 Civic Center Drive
Newport Beach, CA 92660
FTSE(a),newportbeachca.gov
RECEIVED AFTER AGENDA PRINTED
ITEM NO. 16/JUNE 13, 2017
2040 Main Street, Suite 300
Irvine, California 92614
Telephone: 949-852-6700
Facsimile: 949-261-0771
www.watttieder.com
Re: Metro Builder & Engineers Group, Ltd.'s Response to Bid Protest Submitted
by Archio Design Build on Fire Station No.6 Apparatus Bay Replacement
Project, Contract No. 6422
Dear Mr. Tse:
This firm represents Metro Builders & Engineers Group, Ltd. ("Metro Builders") with
respect to the above -referenced matter. This correspondence shall constitute Metro Builders'
response to Archio Design Build's ("Archio's") protest of the low bid submitted by Metro
Builders to the City of Newport Beach ("City") for the Fire Station No. 6 Apparatus Bay
Replacement project (the "Project").
In the bid protest, Archio contends Metro Builders' bid was non-responsive because: (1)
Metro Builders bid bond was signed by SureTec Insurance Company's attorney-in-fact Jase
Hamilton on May 19, 2017, (2) Mr. Hamilton's signature as SureTec's attorney-in-fact was
notarized on May 19, 2017, but (3) SureTec's power of attorney expired on May 18, 2017.
Archio further claims that Metro Builders' bid is defective because Metro Builders bid bond
provided only one corporate officer signature and no corporate seal was applied. The above
rendered the bid bond invalid and unenforceable. As discussed below, Archio's bid protest is
entirely without merit and is an abusive effort to interfere with the City's proper decision to
award the Project to Metro Builders.
As evidenced by SureTec's authenticity letter dated May 30, 2017, Jase Hamilton is
authorized as an attorney-in-fact of SureTec. Mr. Hamilton's authority to sign for and bind
SureTec did not expire on May 18, 2017 but rather remains in effect to date. Moreover, the bid
bond did not expire on May 18, 2017, but remains valid and enforceable pursuant to the
attestation of SureTec and relevant case law. The clerical error in the date of the power of
attorney is an immaterial defect which does not absolve the surety of its obligations under the
bond and which may be waived by the City. Mr. Fouad Houalla would be the only corporate
Mr. Fong Tse
June 9, 2017
Page 2
signature needed on all documents of the bid bond as set forth in Metro Builders' 2016 Board of
Director's and Shareholder's meeting minutes establishing him as the sole corporate officer.
Metro Builders corporate seal was placed on the bid documents, embossed on all necessary
documents of the bid, including the bid bond. Finally, new powers of attorney with an expiration
date of December 31, 2019 were sent on April 5, 2017. Based on the foregoing, and the well-
established California cases which establish that deviations in bids can and should be waived if
such deviations are minor and inconsequential, the City should proceed with awarding the
contract to Metro Builders.
In summary, nothing within Archio's bid protest email constitutes a viable basis for the
City to reject Metro Builders' low bid. Metro Builder has complied with the City's Request for
Proposals ("RFP"), project specifications, and applicable California law. Metro Builders
remains ready, willing, able, and expects to perform the Project in a manner that is consistent
with its bid, the Project specifications, and California law.
I. METRO BUILDERS' BID BOND REMAINS ENFORCEABLE AND IN FULL
EFFECT
In the email Archio's agent argues that the apparent expiration of SureTec's power of
attorney renders Metro Builders' bid bond unenforceable. This unsupported conclusion is
incorrect in light of SureTec's affirmation and attestation of the Mr. Hamilton's power of
attorney and the consequent enforceability of the bid bond, as well as controlling case law.
On its face, the bid bond contains an execution and notarization date of May 19, 2017
with Mr. Hamilton's power of attorney expiration date of May 18, 2017. Despite this facial
defect, however, on May 30, 2017 SureTec confirmed Mr. Hamilton's continuing power of
attorney authority and its intent and agreement to be bound by the terms of the bid bond. On
April 5, 2017, SureTec also sent new powers of attorney with an expiration date of December 31,
2019. A surety may acknowledge its liability and ratification of a bond in retrospect, despite the
alleged invalidity of the signature of its agent. Kadota Fig Ass'n of Producers v. Case -Swayne
Co., 73 Cal. App. 2d 815 (1946).
In Kadota, the surety filed a bond on August 3, 1945 which was signed by a judge
delegated by the agent to execute the bond on the agent's behalf. Id. There was an issue
regarding the validity of the signature. Id. Three days later, on August 6, 1945, the surety filed
and served its duly executed and acknowledged written ratification of the bond. Id. at 821. The
court held that the ratification related back to the date upon which the bond was originally
entered into, and upon which date it purports to have been executed and the bond was found to
be effective from that time. Id. Similarly here, Mr. Hamilton lacked apparent authority to bind
SureTec on Metro Builders' bid bond per the expiration date of May 18, 2017 on the face of the
bond. Nonetheless, SureTec has, a mere eleven (11) days later, acknowledged Mr. Hamilton's
continuing authority, submitted new powers of attorney and ratified the force and effect of the
bond. SureTec's subsequent ratification will relate back to the date upon which the bond was
originally executed — May 19, 2017.
Mr. Fong Tse
June 9, 2017
Page 3
SureTec is not attempting to avoid its obligations under the bond or disputing Mr.
Hamilton's authority. See People v. Surety Insurance Company, 136 Cal. App. 3d 556 (1982)
(surety was not liable on bail bond negotiated and written in the name of its former attorney-in-
fact whose power of attorney had been revoked.). Even if SureTec was disputing the validity of
the bid bond, it would nonetheless still be bound by the bond terms if Metro Builders
subjectively believed Mr. Hamilton had such authority and his authority was objectively
reasonable. See Great American Ins. Co. v. General Builders, Inc., 113 Nev. 346 (1997) (Surety
contract formed and surety bound by same despite power of attorney's lack of actual authority).
Overall, Archio can set forth no case law to dispute a finding of enforceability of the bid
bond. Archio's conclusion that the alleged defect in Metro Builders' bid bond rendered the bond
invalid and unenforceable as a matter of law is simply unsupported.
II. THE CLERICAL ERROR IN METRO BUILDERS' BID BOND IS
IMMATERIAL AND CAN BE WAIVED
The error in the date of Mr. Hamilton's power of attorney authority would be deemed
immaterial in a court of law. Immaterial defects such as these may be waived by the City.
In Menefee v. County of Fresno 163 Cal. App. 3d 1175 (1985) the court held that even a
missing signature on the bid itself (which was specifically required on the bid form) did not
render the bid "invalid" since a signature was not required by another source, such as in the
county regulations controlling the bidding process. Id. at 1179-80. Since there was no regulation
or ordinance requiring a signature on the bid form, the court held that the bid could not be
deemed irregular. Id. at 1180. Even if there were such a regulation or ordinance, the court held
that the subject public agency had "discretion to waive details of the bid specifications if it
determines that such a waiver will not make the bidding process unfair, i.e., if the deviation from
the specifications is inconsequential." Id. (citing 47 Ops.Cal.Atty.Gen. 129 (1966)).
Indeed, such a minor detail is arguably inconsequential and, according to the court in
Valley Crest Landscape v. Davis, 41 Cal. App. 4th 1432 (1996), could be waived:
"... [I]t is further well established that a bid which substantially
conforms to a call for bids may, though it is not strictly responsive,
be accepted if the variance cannot have affected the amount of the
bid or given the bidder an advantage or benefit not allowed other
bidders or, in other words, if the variance is inconsequential."
Id. (citing Konica Business Machines U.S.A., Inc. v. Regents of University of California 206
Cal. App. 3d 449, 454 (1988))(emphasis in the original).
Pursuant to California law, even if the City determines that the power of attorney date
rendered Metro Builders bid bond non-responsive, the City should waive such a minor and
inconsequential irregularity and allow Metro Builders to remain as the lowest, responsible
bidder.
Mr. Fong Tse
June 9, 2017
Page 4
It is well established that a contractor's bid which substantially conforms to an invitation
for bids may, though it is not strictly responsive, be accepted if the claimed errors do not affect
the amount of the bid or give the bidder an advantage that others bidders do not have. See
Ghilotti Construction Co. v. City of Richmond, 45 Cal. App. 4th 897, 904-905 (1996) (citing 47
Ops.Cal.Atty.Gen. 129, 130 (1966). Bid protests must be evaluated from a practical point of
view with an emphasis on the particular facts of the case to determine if an alleged deviation
warrants imposition of a drastic penalty. Ghilotti, 45 Cal. App. 4th at 908. In addition, the bid
protest must be analyzed while considering the public interest:
It certainly would amount to a disservice to the public if a losing
bidder were to be permitted to comb through the bid proposal or
license application of the low bidder after the fact, and cancel the
low bid on minor technicalities, with the hope of securing
acceptance of his, a higher bid. Such construction would be
adverse to the best interests of the public and contrary to public
policy.
Id. at 908-909; see also, Dougherty v. Folk, 46 N.E2d 307, 311 (1941) (it is inconceivable that
inconsequential departures will not appear on bid forms; these minor deviations are not
actionable).
The courts in Ghilotti and Dougherty both ruled that minor deviations are not sufficient
grounds to reject a contractor's bid. Provisions allowing public agencies to waive deviations in
the bid are included to address the often complicated and confusing process of bid proposals.
Bid proposals are submitted under extremely demanding time constraints, and California courts
permit government agencies to waive minor clerical errors or deviations.
Archio has failed to identify any material deviation in Metro Builders' bid. In fact, Metro
Builders' bid complied with the bid solicitation, specifications and governing California legal
requirements. The alleged deviations cited by Archio are inconsequential in that they were not in
violation of any laws, ordinances, or regulations, they had no effect on the amount on the bid and
did not provide Metro Builders with any unfair competitive advantages over other bidders.
III. METRO BUILDERS GAINED NO "UNFAIR ADVANTAGE" OVER OTHER
BIDDERS
Archio cannot establish that Metro Builders received any kind of unfair advantage from
this clerical error. The other bidders were held to the same requirements and standards of having
to issue an enforceable bid bond. Given that SureTec has confirmed, and the case law herein
supports, that the error did not render the bid bond invalid, Metro Builders' bond is no different
than the other bidder's bonds. Metro Builders was the low bidder on the bond and Metro
Builders has not obtained an unfair advantage.
A proper measure of whether the agency's waiver resulted in an "unfair advantage" is
whether the contractor would have been liable on the bid bond if they had attempted to back out
Mr. Fong Tse
June 9, 2017
Page 5
of their bid after it had been accepted by the owner. Menefee v. County of Fresno 163 Cal. App.
3d 1179, 1181 (1985). If the bidder could use the absence of an executing signature on its bid to
avoid a contract, it had an unfair advantage. On the other hand, if the bidder could not use the
absence of a signature to avoid its bid, it did not gain any advantage from the defect, and,
therefore, waiver should be permitted. Id. at 1181.
Here, Archio fails to present any evidence that Metro Builders gained an "unfair
advantage" by the clerical error on the bid bond incorrectly asserting the power of attorney
expired. As stated above, Metro Builders was bound by the same requirements as the other
bidders. Further, there is no evidence to suggest that Metro Builders could use this immaterial
defect as the basis to: (1) retract its bid (after being accepted by the City as the lowest bidder);
and (2) avoid forfeiture of any bid bond. Without this type of showing, Archio has failed to
establish that Metro Builders somehow gained an unfair advantage over the other bidders.
IV. CONCLUSION
For the reasons explained herein, Archio's protest has no merit. Metro Builders' bid was
responsive, and the contract should be awarded to Metro Builders. In fact, a contract awarded to
anyone other than Metro Builders would be illegal and void. See Monterey Mechanical Co. v.
Sacramento Regional County Sanitation District, 44 Cal. App. 4th 1391 (1996). Metro Builders
is a sophisticated contractor with experience in the construction industry, and in bidding projects
of this nature. Metro Builders has assembled a highly qualified team for this Project, and looks
forward to working with the City and delivering a quality Project.
Thank you for your consideration. If you have any questions regarding the above
information, or require additional information from Metro Builders, please do not hesitate to
contact me at (949) 852-6700.
Sincerely,
/s-/ A vnvw day L. M a v't t t34
Amanda L. Marutzky, Esq.
cc:
Fouad Houalla
Metro Builders & Engineers Group, Ltd.
2610 Avon Street
Newport Beach, CA 92663
fouadgmetrobuilders. com
Mr. Fong Tse
June 9, 2017
Page 6
Shelly Irvine
Metro Builders & Engineers Group, Ltd.
2610 Avon Street
Newport Beach, CA 92663
shelly@metrobuilders.com
James Schabarum, Principal
Cavignac & Associates
450 B Street, 18th Floor
San Diego, CA 92101
j schabarumkcavi gnac. com