Rochester City Lines, Co. v. City of Rochester, First Transit, Inc., 868 N.W.2d 655

Rochester City Lines (RCL) challenged City of Rochester’s award of a municipal bus contract via a best-value process guided by the FTA.
FTA directed a competitive bidding process to replace the incumbent contractor for federal funding, leading to a December 2011 RFP that used best-value criteria combining price and qualitative factors.
An evaluation committee ranked First Transit highest, and the City Council awarded the contract to First Transit on April 2, 2012; First Transit began operations July 2, 2012, and RCL ceased fixed-route service the next day.
RCL protested the process, and the district court granted summary judgment in favor of the City and First Transit; the court of appeals affirmed, and this Court granted review to address standard of review and bid-protest review.
The Court adopts Griswold’s unreasonable/arbitrary/capricious standard for best-value awards, and remands for proceedings on RCL’s catch-all evidentiary challenges while upholding other determinations.
Dissent argues for a more deferential view of the best-value process and emphasizes different factual assessments about bias and procedure.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standard of review for best-value bidding	RCL urges robust Griswold review to deter arbitrariness	City/First Transit urge deference to value judgments	Griswold standard applies to best-value awards
Whether irregularities show arbitrariness or bias supporting trial	Evidence supports bias/favoritism against RCL	Irregularities do not prove bias or prejudice	Genuine issues of material fact exist; remand for trial on bias/irregularities
Quasi-judicial challenge to City’s bid denials	City Attorney bias invalidates bid-denial decisions	Bid-denial decisions are quasi-judicial and reviewable by certiorari	District court lacked subject-matter jurisdiction for these claims; affirmed dismissal of this aspect
Organizational conflict of interest by First Transit	First Transit had unfair competitive advantage; improper information sharing	No nonpublic information access or impairment of objectivity established	No organizational conflict of interest; claim failed

Griswold v. Ramsey County, 242 Minn. 529 (Minn. 1954) (unreasonable, arbitrary, or capricious standard for bidding)
Heritage of Am., LLC v. United States, 77 Fed. Cl. 66 (Fed. Cl. 2007) (heavy burden in best-value protest; prejudice required)
PAI Corp. v. United States, 614 F.3d 1347 (Fed. Cir. 2010) (procurement integrity factors for arbitrariness)
In re Excess Surplus Status of Blue Cross & Blue Shield of Minn., 624 N.W.2d 264 (Minn. 2001) (requires rational connection between facts and choice)
O’Malley v. Ulland Bros., 549 N.W.2d 889 (Minn. 1996) (summary-judgment evidentiary standards)
City of Oak Park Heights v. Washington County, 818 N.W.2d 533 (Minn. 2012) (review of quasi-judicial decisions via certiorari)