Marshall v. Pasadena Unified School Dist

In Marshall v. Pasadena Unified School Dist. (2004) 119 Cal.App.4th 1241, a school district used competitive bidding to select a contractor for a school modernization program but later terminated the contract "for the convenience of the District." (Id. at p. 1246.) Two months later, the school district awarded a no bid contract to a competitor by way of an emergency resolution. In holding that the later no bid contract was invalid, the court found that the district's termination of the original contract was not an emergency within the meaning of the code: "That event was not a 'sudden, unexpected occurrence' posing a clear and imminent danger requiring prompt action to protect life, health, property, or essential public services. ." (Id. at p. 1258.)