Weinstein

In February 2012, the County of Los Angeles (County) approved a no-bid contract with Ramsell Public Health Rx, LLC (Ramsell), for pharmacy administrator services to assist the County in implementing provisions of the Patient Protection and Affordable Care Act (ACA) ( Pub.L. No. 111-148 (Mar. 23, 2010) 124 Stat. 119 ). After AIDS Healthcare Foundation (AHF) challenged the award of the contract, the trial court invalidated the contract in June 2012. Days later, the County approved another no-bid contract with Ramsell substantially identical to the first contract, but which had a one-year term. AHF challenged the second contract.

The trial court found that an exception in the Los Angeles County Code permitting no-bid contracts where the contract was for personal services of an “extraordinary and technical nature” and where the services were temporary did not apply because the County had not demonstrated any specialized skills were required to administer the pharmacy benefits under the contract; rather, rudimentary computer and organizational skills were sufficient.

On appeal, the County argues that the trial court failed to accord sufficient deference to the County’s…