Higgins Electric, Inc. v. O'Fallon Fire Protection Dist., No. 15-1222 (8th Cir. 2016)
Annotate this CaseHiggins and the Union filed suit under 42 U.S.C. 1983 and Missouri law against the District, alleging violations of the United States and Missouri Constitutions and state law. The district court dismissed the federal claims under Rule 12(b)(6) and declined to exercise jurisdiction as to the state law claims. The court concluded that the Union does not have standing in this case to pursue its claims on behalf of its members. In regard to Higgins, the court concluded that Higgins failed to state an equal protection claim where the District explicitly reserved the right to award the contract at issue in its best interest, and to select a bidder other than the lowest. The court also concluded that Higgins failed to state a claim for deprivation of due process where, under Missouri law, an unsuccessful bidder obtains no property right in the award of a construction contract, and Higgins failed to state a violation of the First Amendment where it does not provide any plausible account of how the District interfered with Higgins's ability to associate with the Union or with its employees who are members of the Union. Accordingly, the court affirmed the judgment.
Court Description: Riley, Author, with Bye and Benton, Circuit Judges] Civil case - Civil rights.Plaintiff Higgins had standing to bring this civil action alleging the award of a bid violated its civil rights; the plaintiff union did not have standing to pursue relief on behalf of its members because its claim for compensatory damages would be peculiar to the individualized member concerned and both the fact and extent of injury would require individualized proof; plaintiff Higgins failed to state an equal protection claim as the defendant district explicitly reserved the right to award the contact in its best interest and to select a bidder other than the lowest; for the same reason, plaintiff Higgins's due process claim failed; plaintiff Higgins failed to provide any plausible argument for how the district interfered with its ability to associate with the union or its members, and its First Amendment freedom of association claim was properly dismissed.
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