Boise Junior College District v. Mattefs Construction Co.

Idaho Supreme Court

450 P.2d 604 (Idaho 1969)

A bidder who makes an error in preparing a bid for a public works contract is entitled to the equitable relief of rescission if he proves that: (1) the mistake is material, (2) the enforcement of the contract based on the terms of the erroneous bid would be unconscionable, (3) the mistake did not result from violation of a positive legal duty or from culpable negligence, (4) the party to whom the bid is submitted will not be prejudiced except by the loss of his bargain, and (5) prompt notice of the error is given.

Relevant Facts

Mattefs Construction Co. (the defendant) submitted a bid of $141,000 for a construction contract with Boise Junior College District (the plaintiff). The plaintiff was expected to pay $150,000 for the project. The defendant’s bid contained a customary bid bond in which the defendant promised to pay the difference between its bid and the next higher bid actually accepted by the plaintiff if for some reason the defendant refused to contract with the plaintiff. Unbeknownst to the defendant, its bid contained a clerical error which would’ve found the defendant’s expenses to be $151,000 rather than $141,000. Subsequently, the plaintiff awarded the contract to the defendant, but the defendant refused to sign it. The plaintiff then awarded the contract to the next highest bidder at $149,000 and brought suit against the defendant in Idaho state court seeking to recover the difference in price between the defendant’s bid and the next highest bid. The defendant sought the equitable remedy of rescission based on its clerical error. The trial court permitted rescission for the defendant, and the plaintiff appealed.

Issue

Get access to our database of over 17,000+ case briefs today. Access our issue statements for every case you'll encounter in law school for a low monthly price. The largest database on the internet is now available with Lawwly, the central legal hub. Use our case briefs to comprehend your casebook readings in seconds, to supplement your notes and outlines, and to outshine your classmates. No one has a more comprehensive case brief database than Lawwly. All of our briefs are handwritten by real legal experts and law professors and our stringent editing process ensures you'll get the best quality briefs available.

Holding & Reasoning

Get access to our database of over 17,000+ case briefs today. Access holding & reasonings for every case you'll encounter in law school for a low monthly price. The largest database on the internet is now available with Lawwly, the central legal hub. Use our case briefs to comprehend your casebook readings in seconds, to supplement your notes and outlines, and to outshine your classmates. No one has a more comprehensive case brief database than Lawwly. All of our briefs are handwritten by real legal experts and law professors and our stringent editing process ensures you'll get the best quality briefs available.

Concurrence

Get access to our database of over 17,000+ case briefs today. Access all available concurrences for every case you'll encounter in law school for a low monthly price. The largest database on the internet is now available with Lawwly, the central legal hub. Use our case briefs to comprehend your casebook readings in seconds, to supplement your notes and outlines, and to outshine your classmates. No one has a more comprehensive case brief database than Lawwly. All of our briefs are handwritten by real legal experts and law professors and our stringent editing process ensures you'll get the best quality briefs available.

Dissent

Get access to our database of over 17,000+ case briefs today. Access all available dissents for every case you'll encounter in law school for a low monthly price. The largest database on the internet is now available with Lawwly, the central legal hub. Use our case briefs to comprehend your casebook readings in seconds, to supplement your notes and outlines, and to outshine your classmates. No one has a more comprehensive case brief database than Lawwly. All of our briefs are handwritten by real legal experts and law professors and our stringent editing process ensures you'll get the best quality briefs available.

Last updated:

December 29, 2020

Judicial Opinion

Get access to our database of over 17,000 case briefs today. Our database of judicial opinions will be released soon, for free!

Procedural History

Get access to our database of over 17,000+ case briefs today. Access the entire procedural history for every case you'll encounter in law school for a low monthly price. The largest database on the internet is now available with Lawwly, the central legal hub. Use our case briefs to comprehend your casebook readings in seconds, to supplement your notes and outlines, and to outshine your classmates. No one has a more comprehensive case brief database than Lawwly. All of our briefs are handwritten by real legal experts and law professors and our stringent editing process ensures you'll get the best quality briefs available.

Citations

450 P.2d 604 (Idaho 1969)