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Duffy v. Piazza Construction, Inc.
Washington Court of Appeals
815 P.2d 267 (1991)
Richard and James Duffy (plaintiffs) entered into a joint venture with Piazza Construction, Inc. (defendant), memorialized by a letter agreement with Piazza’s president, John Piazza. The purpose of the joint venture was to respond to a United States Forest Service request for proposals for the construction of an office facility. The bid specifications called for proposals with a minimum of 15,500 square feet of net usable office space. According to the letter agreement, the Duffys were to provide land for the proposal, and Piazza was to generate drawings and building specifications. Piazza created two plans that included 15,645 square feet of net usable office space and a third that offered only 15,000 square feet. The smaller plan was based on a diagram of a suggested floor plan furnished by the Forest Service. The Forest Service rejected Piazza’s bid as nonresponsive because it did not meet the minimum square-footage constraint and awarded the project to another bidder. The Duffys filed a lawsuit, claiming that Piazza negligently prepared the bid and was liable for their lost profit. The trial court granted summary judgment to Piazza.
Rule of Law
Holding and Reasoning (Coleman, C.J.)
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