McCormick v. Oklahoma City
Headline: Court dismisses contractor’s federal appeal, holding a dispute over city paving contracts is a state-law contract matter and not a federal constitutional case, leaving the lower-court dismissal in place.
Holding: In this memorandum, the Court held the contractor’s dispute over city paving contracts presented no federal constitutional question and dismissed the federal appeal, leaving the lower-court dismissal in place.
- Leaves city contract disputes to state courts, not federal courts.
- Prevents treating municipal contract breaches as federal due-process violations.
- Affirms lower courts’ dismissal when no binding contract was proven.
Summary
Background
McCormick, a contractor from St. Louis, sued Oklahoma City after he says the city awarded him eighteen paving contracts. He alleges the city council accepted his bids, he prepared and tendered written contracts and bonds, and the acting mayor refused to sign. McCormick says he had begun work, would lose at least $45,000 in expected profit, and that the city’s actions violated both the federal Constitution and Oklahoma law by depriving him of property without due process. The District Court dismissed the suit, and the Circuit Court of Appeals affirmed that dismissal.
Reasoning
The central question was whether this dispute presented a federal constitutional issue or was only a state-law breach of contract. The Court relied on earlier decisions saying a city’s refusal to perform a contract is not automatically a law that impairs contracts or a taking of property without due process. Because McCormick’s allegations amounted to a claimed contract breach rather than a federal constitutional violation, the case involved only diversity of citizenship and not a federal question. The Supreme Court therefore treated the circuit court’s decree as final and dismissed the appeal. The lower courts also found that no binding contracts had been consummated.
Real world impact
The decision leaves the lower courts’ dismissal in place and means the contractor cannot force city performance through a federal constitutional claim. Disputes over municipal contract awards will normally be resolved under state law and in state courts unless a clear federal constitutional right is shown.
Ask about this case
Ask questions about the entire case, including all opinions (majority, concurrences, dissents).
What was the Court's main decision and reasoning?
How did the dissenting opinions differ from the majority?
What are the practical implications of this ruling?