Martin Engineering v. Lexington County School District One

A South Carolina school district (defendant) solicited bids for a school-renovation project. Sharp Construction Company (Sharp) (defendant) was the lowest bidder, bidding $16.3 million. Immediately after the bids were unsealed, Sharp added approximately $600,000 to its bid, stating it had omitted the cost of its roofing subcontractor. Sharp had named the subcontractor in its bid but omitted the amount for the subcontractor’s work. The $600,000 figure Sharp added for the roofing subcontractor matched an identical figure in several of the other bids for roofing work by the same subcontractor. The school district granted Sharp’s request to adjust its bid upward by $600,000 to correct the mistake. Even with the upward adjustment, Sharp remained the lowest bidder by over $460,000. The school district accepted Sharp’s adjusted bid. The second-lowest bidder, Martin Engineering (Martin) (plaintiff), had placed a bid for approximately $17.3 million. Martin sued Sharp and the school district in state court, alleging Sharp’s bid correction threatened the integrity of the bidding process. Martin asked the court to order the school district to reject Sharp’s bid and accept Martin’s bid instead. Sharp and the school district filed a motion for summary judgment, seeking dismissal of Martin’s claim on the ground that the bid adjustment was appropriate. The trial court granted summary judgment. Martin appealed to the state appellate court. The South Carolina Supreme Court certified the question of whether the trial court erred in holding that the school district properly allowed the bid adjustment.