Heery International, Inc. v. Montgomery County, Maryland, 384 Md. 129

Summary

The Court of Appeals of Maryland held that Heery International and HOK were required to exhaust Montgomery County's administrative contract-dispute process before seeking judicial intervention. The court concluded that the County's administrative adjudicators were not "palpably without jurisdiction" to decide whether the County Code and procurement regulations authorized the County to assert claims against contractors. The court emphasized that this issue involved statutory interpretation and should initially be decided by the agency, subject to later judicial review.

Holdings

1. The County administrative process was not palpably without jurisdiction. The contractors failed to show that the agency was clearly and unequivocally outside its fundamental jurisdiction.
2. Heery was required to exhaust the County administrative remedies before seeking judicial review or intervention because no exception to exhaustion applied.
3. The contractors did not demonstrate irreparable injury, an inadequate administrative remedy, or the absence of judicial review sufficient to justify bypassing the administrative process.

Questions Presented

1. Whether the Montgomery County Department of Public Works and Transportation administrative dispute-resolution process was palpably without jurisdiction to adjudicate claims initiated by the County against a contractor.
2. Whether Heery could obtain judicial intervention before exhausting the County's administrative dispute-resolution process.
3. Whether the question whether the County Code and Procurement Regulations authorize County-initiated claims was a fundamental jurisdictional issue or a statutory interpretation and application issue for initial administrative determination.

Disposition

affirmed