Judge: Stephen I. Goorvitch, Case: 24STCP04154, Date: 2025-03-14 Tentative Ruling

Case Number: 24STCP04154    Hearing Date: March 14, 2025    Dept: 82

Paveco Construction, Inc.                                        Case No. 24STCP04154

 

v.                                                                     Hearing: March 14, 2025

                                                                        Location: Stanley Mosk Courthouse

Los Angeles Department of                                     Department: 82                                     

Water and Power                                                      Judge: Stephen I. Goorvitch           

 

[Tentative] Order Granting SEP’s Motion to Quash

 

[Tentative] Order Authorizing Limited Discovery

 

INTRODUCTION

 

            Petitioner Paveco Construction, Inc. (“Petitioner”) filed a petition for writ of mandate challenging a decision by the Los Angeles Department of Water and Power (“Respondent” or “DWP”) to award a construction contract to another bidder, S E Pipe Line Construction Company (the “Real Party” or “SEP”).  SEP’s subcontractors include Mallard Construction, Inc. (“Mallard”), whose president is Samuel Mullen (“Mullen”), as well as Sully-Miller Contracting dba Blue Diamond Materials (“Blue Diamond”) and Vulcan Materials Company (“Vulcan”).  Petitioner served subpoenas to take depositions of the Person Most Knowledgeable (“PMK”) for Mallard, Blue Diamond, and Vulcan, as well as a subpoena to take the deposition of Mullen.  Now, SEP moves to quash these subpoenas.  The motion is granted.  However, the court authorizes Petitioner to propound certain Requests for Production of Documents upon SEP and the DWP. 

             

PETITIONER’S ALLEGATIONS

 

            On or about December 19, 2023, DWP issued an invitation for bids (“IFB”) from contractors for an award of a contract known as the “Blowout Pavement Repairs.”  (Petition

¶ 14.)  The IFB required bidders to comply with LADWP’s rules for participation from a Small Business Enterprise (“SBE”) or a Disabled Veran Business Enterprise (“DVBE”).  (Id. ¶ 4 and Exh. A.)  The IFB requires the SBE/DVBE subcontractors to perform at least 20% of the total amount of the contract; requires the subcontractors to perform “a commercially useful function;”  and requires the bidder to submit a “Letter of Intent” showing “confirmation from a sub-listed SBE or DVBE that it is willing to participate in the contract.”  (Id. Exh. A at B2-1, B2-3, and B2-4.)  The IFB defines “commercially useful function” as follows:

 

Responsibility for the execution of a distinct element of work of the contract, which is carried out by actually performing, managing, and supervising the work involved, or fulfilling responsibilities as a Joint Venture partner, and has a necessary and useful role and the firm’s role is not superfluously added in an attempt to meet credit toward achievement of the contract-specific mandatory SBE and/or DVBE requirement.

 

(Id. at B2-2.)

 

 

Two contractors—Petitioner and SEP—submitted bids in response.  (Id. ¶ 15.)  SEP’s bid was lower than Petitioner’s bid.  (Id. ¶ 16.)  DWP awarded the contract to SEP.  (Id. ¶ 17.)  On March 8, 2024, Petitioner submitted a bid protest and made a request under the California Public Records Act (the “CPRA”) seeking copies of public documents regarding the bids.  (Ibid.)  The protest states as follows:

 

[A]t this time, we are protesting the following: (i) One that [SEP] did not meet the 20% Mandatory SBE / DVBE Participation Requirement for this Contract; [and] (ii) Two that LADWP is in violation of the “California Public Records Act” and is withholding records without due cause.

 

(Petition Exh. B at 2.)  Then, on March 27, 2024, Petitioner made a supplemental bid protest.  (Id. ¶ 18.)  The supplement states as follows:

 

            [T]he facts and law unequivocally show that SEP did not meet the mandates set forth in the Bid Invite or the requirements set forth in multiple statutes and codes. 

 

            . . .

 

            d.         DWP’s Bid Invite required 20% SBE/DVBE participation. 

 

            . . .

 

            g.         SEP provided Letters of Intent by the following entities with the following participation percentages in its attempt to meet DWP’s 20% SBE/DVBE participation mandates:

 

                        i.          Mallard Construction:            18.0%

                        ii.         Lindy’s Cold Planing:              3.0% 

                        iii.       Smithson Electric:                    1.0%                         

                                                                                     22.0%

           

            h.         SEP’s bid list both Mallard Construction and Lindy’s Cold Planing as “Asphalt Material Suppliers.”

           

            i.          Per DWP’s Bid Invite and Public Contract Code Section 2002(d), material suppliers do not provide a Commercial Useful Function. . . .  Per SEP’s bid both Mallard Construction and Lindy’s Cold Planing are simply providing asphalt supplies, neither will be performing, managing, or supervising any work.

 

            j.          Thus, neither Mallard Construction, nor Lindy’s Cold Planing, provide a Commercial Useful Function.

 

            . . .

 

           

In addition, even if one were to argue that Mallard Construction and Lindy’s Cold Planing did not provide Commercial Useful Functions, SEP’s bid still fails to meet the mandates of the Bid Invite because SEP alleges that Mallard Construction and Lindy’s Cold Planing are “Asphalt Material Suppliers,” and in order for them to be considered legitimate “Asphalt Material Suppliers,” they must be in the business of manufacturing asphalt materials, not just trucking them. . . .

 

(Petition Exh. C.)      

 

On December 19, 2024, Petitioner filed this action challenging the LADWP’s denial of the appeal pursuant to Code of Civil Procedure section 1085.  (Id. ¶¶ 83-92.)  On or about January 30, 2025, Petitioner served the deposition subpoenas seeking the deposition and production of documents from Mallard’s PMK and from Samuel Mullen, Mallard’s CEO/President.  (Lee Decl. ¶¶ 2-3, Exh. 1-2.)  On or about February 3, 2025, Petitioner served the deposition subpoenas seeking the deposition and production of documents from the PMKs of Vulcan Materials Company and Sully-Miller Contracting dba Blue Diamond.  (Id. ¶¶ 4-5, Exh. 3-4.)  On February 10, 2025, SEP filed the instant motion to quash.

 

LEGAL STANDARD

 

A.        Writ of Mandate

 

The petition for writ of mandate is brought pursuant to Code of Civil Procedure section 1085.  There are two essential requirements to the issuance of an ordinary writ of mandate under Code of Civil Procedure section 1085: (1) a clear, present, and ministerial duty on the part of the respondent, and (2) a clear, present, and beneficial right on the part of the petitioner to the performance of that duty.  (California Ass’n for Health Services at Home v. Department of Health Services (2007) 148 Cal.App.4th 696, 704.)  Generally, mandamus is available to compel a public agency’s performance or to correct an agency’s abuse of discretion when the action being compelled or corrected is ministerial.”  (AIDS Healthcare Foundation v. Los Angeles County Dept. of Public Health (2011) 197 Cal.App.4th 693, 700.)   

 

An agency is presumed to have regularly performed its official duties.  (Evid. Code § 664.) Generally, the petitioner “bears the burden of proof in a mandate proceeding brought under Code of Civil Procedure section 1085.”  (California Correctional Peace Officers Assn. v. State Personnel Bd. (1995) 10 Cal.4th 1133, 1154.)  A reviewing court “will not act as counsel for either party to an appeal and will not assume the task of initiating and prosecuting a search of the record for any purpose of discovering errors not pointed out in the briefs.” (Fox v. Erickson (1950) 99 Cal.App.2d 740, 742.)

 

B.        Motion to Quash Deposition Subpoena

 

For good cause shown, the court may enter a protective order or an order quashing a subpoena to prevent unwarranted annoyances, embarrassment, oppression, undue burden, and expense in discovery.  (Fireman’s Fund Ins. Co. v. Superior Court (1991) 233 Cal.App.3d 1138, 1141; see also Code Civ. Proc. § 2025.420(b), § 2017.020(a), § 1987.1.)  The moving party has the burden to show good cause for a protective order or an order quashing a deposition subpoena. (See Emerson Elec. Co. v. Sup. Ct. (1997) 16 Cal.4th 1101, 1110; Weil & Brown, Civ. Pro. Before Trial (The Rutter Group 2011) ¶ 8:689.)

 

C.        Discovery in Administrative Proceedings

 

In this action, Petitioner seeks a writ of ordinary mandate pursuant to Code of Civil Procedure section 1085 commanding LADWP to award the Blowout Pavement Repairs contract to Petitioner and not SEP.  (Pet. Prayer ¶¶ 2, 3.)  Judicial review “under Code of Civil Procedure section 1085 is limited to determining whether the public agency’s action was arbitrary, capricious, entirely without evidentiary support, or procedurally unfair.”  (Federation of Hillside & Canyon Assns. v. City of Los Angeles (2004) 126 Cal.App.4th 1180, 1195 [internal citations omitted].)  Further, the court “must ensure that the agency adequately considered all relevant factors, and demonstrated a rational connection between those factors, the choice made, and the purposes of the enabling legislation.”  (Coachella Valley Unified School Dist. v. State of California (2009) 176 Cal.App.4th 93, 121.) 

 

“An unbroken line of cases holds that, in traditional mandamus actions challenging quasi-legislative administrative decisions, evidence outside the administrative record ‘extra-record evidence’ is not admissible.”  (Carrancho v. California Air Resources Board (2003) 111 Cal.App.4th 1255, 1269.)   These restrictions do not apply, however, to ministerial or informal administrative actions.  As stated by our Supreme Court, “we will continue to allow admission of extra-record evidence in traditional mandamus actions challenging ministerial or informal administrative actions if the facts are in dispute.”  (Western States Petroleum Assn. v. Superior Court (1995) 9 Cal.4th 559, 576.)  This is because “when the courts are asked to review ministerial or informal administrative actions, … there is often little or no administrative record in such cases.  (Id. at 575.) 

 

In addition, there is an exception for extra-record evidence in traditional mandamus proceedings involving quasi-legislative decisions “in which (1) the evidence in question existed before the agency made its decision, and (2) it was not possible in the exercise of reasonable diligence to present this evidence to the agency before the decision was made so that it could be considered and included in the administrative record.”  (Western States, supra, 9 Cal.4th at 578.)  Furthermore, extra-record evidence may be admissible and “relevant to (1) issues other than the validity of the agency’s quasi-legislative decision, such as the petitioner's standing and capacity to sue, (2) affirmative defenses such as laches, estoppel and res judicata, (3) the accuracy of the administrative record, (4) procedural unfairness, and (5) agency misconduct.”  (Id. at 579, fn. 5.) 

 

Although there is no express provision allowing discovery in an administrative mandamus proceeding, section 1094.5, subdivision (e) has been interpreted to allow limited posthearing discovery provided the moving party shows that such discovery is reasonably calculated to lead to evidence admissible under section 1094.5…. [D]iscovery under section 1094.5, unlike general civil discovery, cannot be used to go on a fishing expedition looking for unknown facts to support speculative theories.  The stringent requirements set forth in section 1094.5, subdivision (e) require the moving party to identify what evidence is sought to be discovered for purposes of adding it to the record; to establish the relevancy of the evidence; and to show that either (a) any such relevant, additional evidence was improperly excluded at the administrative hearing, or (b) it could not have been produced at the hearing with the exercise of reasonable diligence. (Code Civ. Proc. § 1094.5, subd. (e).) If the moving party fails to make the required showing, it is an abuse of the court's discretion to allow posthearing discovery. 

 

(Pomona Valley Hospital Medical Center v. Superior Court (1997) 55 Cal.App.4th 93, 102.)  Most important, “extra-record evidence can never be admitted merely to contradict the evidence that the administrative agency relied on in making a quasi-legislative decision or to raise a question regarding the wisdom of that decision.”  (Western States, supra, 9 Cal.4th at 579.)      These same rules apply to a petition for writ of traditional mandate pursuant to Code of Civil Procedure section 1085.  (See Cadiz Land Co. v. Rail Cycle, L.P. (2000) 83 Cal.App.4th 74, 120 [“Regardless of whether common law principles under Western States apply or the action is subject to Code of Civil Procedure section 1094.5, subdivision (e), the underlying principles in determining whether extra-record evidence is admissible are essentially the same.”].)

 

EVIDENTIARY ISSUES

 

            Petitioner requests judicial notice of Respondent’s opposition to Petitioner’s ex parte application for a temporary restraining order is granted.  There is no opposition to the request.  The court grants the request under Evidence Code section 452(c). 

           

DISCUSSION

 

            The dispositive issue in this writ proceeding is not whether Mallard performs a commercially useful function.  Rather, the dispositive issue is whether DWP’s finding that Mallard performs a commercially useful function was “arbitrary, capricious, entirely without evidentiary support, or procedurally unfair,” and whether DWP “adequately considered all relevant factors” in making this decision.  This will entail a review of the information DWP considered at the time it made the decision.  In other words, the court will review the evidence in the administrative record and determine whether DWP’s finding constitutes an abuse of discretion.  The court agrees with DWP’s argument that the issue is whether DWP “engaged in misconduct in approving the contract award to SEP,” not whether SEP or Mallard engaged in misconduct.  (See DWP’s Joinder to Motion to Quash at 6:19-20.)    

 

It is undisputed that an administrative hearing was not held in this case.  Administrative actions that do not involve public hearings have often been deemed “informal” such that the general prohibition on extra-record evidence, or the “closed record rule,” does not apply.  (California Oak Foundation v. Regents of Univ. of Cal. (2010) 188 Cal.App.4th 227, 255-56.)  [B]ecause the record upon which a public agency’s informal action is based is often inadequate to permit meaningful review, the court presiding over traditional mandamus proceedings challenging the agency’s informal action is generally permitted to consider extra-record evidence if the facts are in dispute.”  (Ibid.)  However, an agency is not required to hold a live, evidentiary hearing in order for the “closed record rule” to apply.  (Carrancho v. California Air Resources Board  (2003) 111 Cal.App.4th 1255,1270-71 [“While it is true that neither agency held a formal hearing ... [t]he trial court correctly ruled that extra-record evidence was not admissible”].) 

 

In this case, there was a sufficient level of formality to invoke the “closed record rule.”  The DWP issued an IFB, and in response, contractors submitted information to the DWP.  There is an administrative record in this case reflecting the information the DWP considered.  If the administrative record is lacking, as suggested by Petitioner, that would benefit Petitioner’s argument that the DWP’s finding was “arbitrary, capricious, entirely without evidentiary support, or procedurally unfair.”

 

 Petitioner attempts to involve exceptions that would permit discovery.  The California Supreme Court has recognized an exception for evidence that could not be produced at the administrative level in the exercise of reasonable diligence, but that still requires Petitioner to comply with Code of Civil Procedure section 1094.5(e):

 

Extra-record evidence is admissible under this exception only in those rare instances in which (1) the evidence in question existed before the agency made its decision, and (2) it was not possible in the exercise of reasonable diligence to present this evidence to the agency before the decision was made so that it could be considered and included in the administrative record.

 

(Western States, supra, 9 Cal.4th at 578.)  Petitioner cannot demonstrate that the depositions or expansive requests for production satisfy these requirements. 

 

            More important, Petitioner seeks to violate the rule that “extra-record evidence can never be admitted merely to contradict the evidence that the administrative agency relied on in making a quasi-legislative decision or to raise a question regarding the wisdom of that decision.”  (Western States, supra, 9 Cal.4th at 579.)  Essentially, Petitioner seeks to develop evidence that Mallard does not actually perform a commercially useful function to contradict the evidence upon which DWP relied in making a contrary finding.  This is not permissible.  As discussed, the dispositive issue is not whether Mallard actually performs a commercially useful function; the dispositive issue is whether DWP had sufficient evidence to make that finding. 

 

            Petitioner produces an exchange of emails between LADWP and SEP starting June 21, 2024, 11 days after LADWP denied Petitioner’s bid protest, which may support Petitioner’s position that LADWP did not have sufficient information to conclude that Mallard would complete 18% of the 20% SBE/DVBE participation requirement for the contract.  (See Pet. Oppo. 6-7; Carno Decl. ¶¶ 21-25, Exh. C.)  These documents appear to have been included in the supplemental administrative record.  (Carno Decl. Exh. C.)  If not, Petitioner may seek to augment the record with these emails.

           

Based upon the foregoing, the court grants SEP’s motion to quash the subpoenas issued to Mallard, Mullen, Blue Diamond, and Vulcan.  However, the court agrees that some limited discovery may be appropriate.  Therefore, the court authorizes the following Requests for Production of Documents (“RPDs”).

           


 

A.        RPDs to DWP

 

                        1.         Produce all non-privileged documents upon which you relied in awarding the contract that are not already contained within the administrative/supplemental administrative record.

 

                        2.         Produce all non-privileged documents upon which you relied in finding that Mallard performs a commercially useful function that are not already contained within the administrative/supplemental administrative record.

 

            B.        RPDs to SEP

 

                        3.         Produce all documents you provided to DWP in connection with your bid, including any in relation to Petitioner’s bid protest, that are not already contained within the administrative/supplemental administrative record.

 

                        4.         Produce all documents you provided to DWP with respect to the issue whether Mallard performs a commercially useful function that are not already contained within the administrative/supplemental administrative record.

 

CONCLUSION AND ORDER

 

            Based upon the foregoing, the court orders as follows:

 

            1.         The court grants SEP’s motion to quash the subpoenas issued to Mallard, Mullen, Blue Diamond, and Vulcan.

 

            2.         The court orders SEP and DWP to comply with the Requests for Production of Documents on or before March 21, 2025.  If necessary, Petitioner may file a motion to augment the administrative record.   

 

            3.         SEP and DWP shall file a status report discussing whether any documents were produced in response to these RPDs and, if so, provide an index of the documents.  The joint status report shall be filed on or before March 21, 2025.   

 

            4.         The court continues the trial setting conference to March 28, 2025, at 9:30 a.m.

 

            5.         The court’s clerk shall provide notice.    

 

 

IT IS SO ORDERED

 

 

Dated: March 14, 2025                                               ______________________

                                                                                    Stephen I. Goorvitch

                                                                                    Superior Court Judge