Cobb v. Pasadena City Bd. of Education

In Cobb v. Pasadena City Bd. of Education (1955) 134 Cal.App.2d 93, the court considered whether a school board was required to seek competitive bids to employ an architect to prepare plans for the school's expansion. (Id. at p. 94.) Cobb reiterated the principle that it was well settled that "because an architect is an artist, that his work requires taste, skill and technical learning and ability of a rare kind, it would be bad judgment to advertise and get many bids when the lowest bidder might be also the least capable and most inexperienced and his bid absolutely unacceptable ... ." (Id. at p. 95.) Thus, "'the employment of a person who is highly and technically skilled in his science or profession is one which may properly be made without competitive bidding.' " (Ibid.) Notably, Cobb rejected the contention that the competitive bidding requirement for construction contractors automatically meant that an architect's services could only be employed by competitive bidding. "Where competitive proposals do not produce an advantage, a statute requiring competitive bidding does not apply." (Ibid.)