Holly's Inc. v. County of Greensville

In Holly's Inc. v. County of Greensville (VA 1995) 250 Va. 12, 458 S.E. 2d 454, the bid notice stated that "On Thursday, March 17, 1994 at 2:00 p.m. all bids received ... will be opened" (id. at p. 455), but the bidder's bid was not received until 2:02 p.m. or 2:03 p.m. (Id. at p. 456.) The Virginia Supreme Court rejected the bidder's argument that its bid was timely and concluded in part that the bid documents required bids to be submitted before 2:00 p.m. because "a bid could not be opened at 2:00 p.m. unless it was received before 2:00 p.m." (Id. at p. 457.)