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City of Jacksonville v. Reynolds, Smith & Hills, Architects, Engineers & Planners, Inc.

Citations: 424 So. 2d 63; 1982 Fla. App. LEXIS 21768Docket: No. AL-17

Court: District Court of Appeal of Florida; December 9, 1982; Florida; State Appellate Court

Narrative Opinion Summary

The case involves an appeal by the City of Jacksonville concerning the validity of certain provisions of Ordinance 130.301 et seq., which regulate Professional Services Contracts in relation to the Consultants’ Competitive Negotiations Act (Section 287.055, Florida Statutes). The dispute arose when engineering firms challenged the ordinance's requirement for fee quotations before negotiations, arguing it contradicted the Act. The circuit court had initially declared these ordinance provisions invalid. However, upon appeal, the reviewing court found that the ordinance did not conflict with the Act. The court concluded that the Act allows for the inclusion of budget considerations, such as fee quotations, in the selection process, which the ordinance mandates. Consequently, the court reversed the circuit court's decision, upholding the ordinance's validity and allowing the City to incorporate fee considerations in its selection process. The decision was concurred by Chief Judge Smith and Judge McCord, affirming the City's approach did not contravene statutory requirements.

Legal Issues Addressed

Conflict Between Ordinance and State Statute

Application: The court examined whether the City's ordinance was inconsistent with the state statute governing competitive negotiations and concluded that it was not.

Reasoning: The judgment is reversed, affirming that the ordinance does not conflict with the Act and that the City can include fee considerations in its selection process.

Consultants’ Competitive Negotiations Act Interpretation

Application: The court interpreted the Act to allow for flexibility in the selection process, permitting consideration of factors not explicitly listed, such as fee quotations.

Reasoning: It noted that the Act allows for considerations beyond those explicitly listed, including budget factors, and found no legislative prohibition against the City’s approach to considering fees early in the selection process.

Validity of Fee Quotations Requirement

Application: The court found that requiring fee quotations prior to negotiations does not undermine the competitive selection process as outlined by the state statute.

Reasoning: The court determined that the ordinance's requirement for fee quotations does not undermine the competitive selection process outlined in the Act.