AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• RMCI, General Contractors, Inc. (RMCI) contested the award of a public works project contract by the Albuquerque Bernalillo County Water Utility Authority (the Water Authority) to Archer Western Contractors, Ltd. (Archer). RMCI argued that the bidding process violated state and local law and that Archer's bid was non-responsive due to a date discrepancy on its bid bond. The Water Authority had solicited bids for the project, which was the final phase of a multi-phase project aimed at preserving and protecting a drought reserve. RMCI and Archer submitted the two lowest bids, but RMCI's bid was deemed non-responsive due to a failure to provide requested information on similar project performance and superintendent qualifications. The Water Authority awarded the contract to Archer, finding it to be the lowest responsible bidder. RMCI sought injunctive and declaratory relief in district court, which was denied on the grounds of lack of standing and failure to exhaust administrative remedies (paras 1-5).

Procedural History

• District Court of Bernalillo County, Clay P. Campbell, District Judge: Denied RMCI's request for injunctive relief and dismissed the complaint for lack of standing and failure to exhaust administrative remedies (para 6).

Parties' Submissions

• Plaintiff-Appellant (RMCI): Argued that the Water Authority's bidding process violated state and local law and contested Archer's qualifications as a bidder due to a date discrepancy on its bid bond (paras 1, 4).
• Defendants-Appellees (Water Authority and Archer): Defended the bidding process and the award of the contract to Archer, asserting that the date discrepancy on Archer's bid bond was a de minimis technical irregularity and that RMCI lacked standing to challenge the award due to failure to exhaust administrative remedies (paras 3-5, 6).

Legal Issues

• Whether the district court erred in denying RMCI's requests for injunctive and declaratory relief on the grounds of mootness, lack of standing, and failure to exhaust administrative remedies (paras 7-21).

Disposition

• The Court of Appeals affirmed the district court's decision, concluding that the issues raised were moot and that RMCI lacked standing to challenge the award of the contract due to failure to exhaust administrative remedies (para 21).

Reasons

• The Court of Appeals, per Judge Timothy L. Garcia, with Judges Michael D. Bustamante and Michael E. Vigil concurring, held that the appeal was moot because the contract had already been awarded to Archer and construction had begun. The court found that RMCI lacked standing to challenge the award because it failed to exhaust its administrative remedies and did not timely protest the Water Authority's intention to reject RMCI's bid as non-responsive. The court also noted that even if RMCI had been found to be a responsible bidder, there was no meaningful remedy that could be awarded at this stage, as the contract had already been executed and work performed. The court declined to consider a new claim against Archer raised for the first time on appeal and found no exception to the mootness doctrine applicable under the circumstances (paras 8-21).