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Valle-Axelberd & Associates, Inc. v. Metropolitan Dade County
Citations: 440 So. 2d 606; 1983 Fla. App. LEXIS 24165Docket: No. 83-262
Court: District Court of Appeal of Florida; November 7, 1983; Florida; State Appellate Court
Valle-Axelberd appeals the denial of injunctive relief regarding its bid for a contract to provide psychological screening devices for police applicants. Dade County, after evaluating bids, awarded the contract to the second lowest bidder, Psychological Resources/Psychological Associates of Miami, due to concerns about the Minnesota Multiphasic Personality Inventory (MMPI) being perceived as racially biased. The court rejected the argument that the contract involved professional services exempt from bidding requirements, affirming that the county chose to solicit bids and had outlined additional evaluation criteria, including professional experience in law enforcement and the multicultural setting. The trial court found no evidence of arbitrary or capricious behavior in the county’s decision, which allowed for discretion in awarding the contract based on factors beyond price. The ruling is supported by precedents that allow local government discretion in contracting decisions. The court's decision to uphold the contract award is affirmed.