To: Myron Gibbons
From: Don Doddington
Re: SWFWMD Peace River Basin
August 16, 1971
ISSUE: When a public body desires the services of n aerial
photographer, must they comply with the requirements of competitive
ANSWER: Probably not.
The only florida case dealing with this subject sta
general rule that contracts for services requiring speci
training are not required to be let on bid. Parker vs.
(1963) 151 So.2d 469. The case listed examples or vario'
and professions that were included in this category. Al
list is not all inclusive, it does mention surveyors, wh
somewhat analogous to aerial photographers.
In People Exrel Smith vs. Flagg (1858) 17 NY 584, a
for the services of a surveyor to prepare maps was held
which the City could make without first calling for bids
Similarly, in Wallace vs. Commissioner's Court (19
app.) 281 SW 593, a contract with certain individuals by
to prepare a complete abstract of property assessed with
County, make a complete map and plat system of the land
pare proper description of the land, was found not to re
The Court reasoned that no bidding is required where the
quired demanded technical skills or knowledge.
Ll skills or
to be one
26 tex. civ.
and to pre-
Considering the range of vocations and professions included in
this exception to competitive bidding and keeping in mind the specialized
and technical nature of aerial photography, it would appear that
competitive bidding would not be required in this instance.