Background
The University of Maine System selected Calvary Chapel Belfast as the winning bidder for the Frederick Hutchinson Center property in August 2024. Following significant public outcry and protests from other bidders alleging religious bias, the university rescinded the award and initiated a new procurement process. Calvary Chapel Belfast sued in federal court, seeking to halt the sale and restore its winning bid, alleging the university’s decision was driven by unconstitutional anti-religious bias in violation of the Equal Protection and Free Exercise Clauses.
The court’s reasoning
The First Circuit reviewed the district court’s denial of a preliminary injunction for abuse of discretion. The court affirmed that the district court correctly applied the totality-of-the-circumstances test to assess discriminatory intent. The appellate court found no error in the district court’s conclusion that the university’s Vice Chancellor was motivated solely by cost savings when rescinding the award, rather than by community animus. The court held that the presence of community opposition does not automatically imply that government officials acted with discriminatory intent absent evidence of procedural irregularities or a departure from normal decision-making factors.
The fact that there was religious animosity present in the community and even argued to the University by Waldo and Waterfall Arts as a basis for appeal cannot mean that the University is locked into a decision that it determined would result in a substantial net financial loss for it when there is no other evidence to suggest it acted on impermissible motives.
Calvary Chapel Belfast v. Univ. of Me. Sys., No. 24-cv-00392, 2025 WL 71701, at *9 (D. Me. Jan. 10, 2025)
What it means going forward
The decision upholds the university’s authority to rescind a procurement award based on financial considerations even in the face of public controversy, provided there is no evidence that the decision was actually driven by religious bias.