Syringa Networks, LLC v. Idaho Department of Administration
159 Idaho 813
| Idaho | 2016Background
- IEN is a statewide education network overseen by DOA, using open competitive bidding for telecommunications services.
- DOA issued an RFP in 2008 seeking end-to-end bids; Syringa could not provide end-to-end service and agreed to be ENA's subcontractor.
- In 2009 DOA issued SBPOs to Qwest and ENA as a multiple award; in Feb 2009 DOA amended SBPOs to divide work between ENA and Qwest, removing Syringa’s planned role.
- Syringa sued DOA, Qwest, ENA, and DOA employees; Syringa I held Syringa had standing to pursue Count Three and remanded for further proceedings.
- On remand, district court held the amendments/underlying contracts void for procurement-law violations, denied repayment relief, and awarded Syringa attorney fees; multiple parties appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Procedural propriety of voiding SBPOs on remand | Syringa argues district court properly voided SBPOs under law as unlawfully amended. | DOA/ENA/Qwest contend court lacked jurisdiction or erred in handling remand procedures. | Procedurally proper; court had jurisdiction to void as amended. |
| Substantive correctness of voiding SBPOs | Syringa contends amendments violated procurement law and thus void ab initio. | Defendants dispute illegality and argue remedy should be severance or upholding parts not tainted. | SBPOs as amended were void; the procurement violations tainted the contracts. |
| Whether district court erred in denying repayment order | Syringa sought DOA to demand repayment of funds advanced under void SBPOs. | DOA/Qwest/ENA argue the court lacked authority or that mootness precludes relief. | No reversible error; district court correctly refused to order repayment. |
| Attorney fees on remand; prevailing party | Syringa should recover fees as prevailing party under statutes 12-117, 12-120(3), 12-121. | DOA challenges reasonableness and appropriateness of fee award and prevailing-party status. | Syringa prevailing; fee award upheld; no fees awarded on appeal to any party. |
| Law of the case and standing on remand | Syringa argues Syringa I did not conclusively decide merits; standing determined by context. | Defendants contend law-of-the-case forecloses certain challenges. | Law of the case does not bind the remand; summary judgment on illegality proper based on facts. |
Key Cases Cited
- Syringa Networks, LLC v. Idaho Dep't of Admin., 155 Idaho 55 (Idaho 2013) (standing and procurement-law discussion in Syringa I)
- Quiring v. Quiring, 130 Idaho 560 (Idaho 1997) (public-policy illegality not waivable; court must act against illegality)
- City of Meridian v. Petra Inc., 154 Idaho 425 (Idaho 2013) (contract validity despite statutory bonding violations; focus on purpose and legality)
- Thompson v. Ebbert, 144 Idaho 315 (Idaho 2007) (contracts illegal or void; contracts deemed never to have existed when void)
- McQuillin on Municipal Corporations, unreported treatise cited () (public bidding deviations require readvertisement to maintain fairness)