Wilson v. Los Angeles County Metropolitan Transportation Authority

Opinion

BROWN, J.

We consider in this case whether the lowest responsible bidder that is wrongfully denied a public contract has a cause of action for monetary damages against the public entity, and if so, whether those damages include bid preparation costs and lost profits. We conclude bid preparation costs but not lost profits are available under a theory of promissory estoppel. We therefore reverse the judgment of the Court of Appeal.

I. Factual and Procedural Background

In April 1994, the Los Angeles Metropolitan Transportation Authority (MTA) solicited bids to build the Red Line…