Chandler v. Otto
Supreme Court of Washington
693 P.2d 71 (1984)
The City of Moses Lake sought bids for solid-waste handling; after the two lowest bidders failed to sign every page as required, the city council voted 4-3 to disqualify them and awarded the contract to the third-lowest bidder, which was $180,000 more expensive than the lowest bid. A recall petition was filed against the four councilmen (defendants) who voted for the award, alleging their decision was an abuse of discretion. Under Washington's recall statute, the trial court held the charges legally sufficient, and the councilmen appealed.
Whether a public official may be recalled only for substantial conduct amounting to misfeasance, malfeasance, or violation of the oath of office, rather than for appropriately exercising discretion the law grants the official.