Young v. Chao
- Joseph Spero
- 3:19-cv-01411
- U.S. District Court · Northern District of California
- 5
In Young v. Buttigieg, Judge Spero denied Cheryl Young’s request to overturn taxed costs and ordered her to pay $4,034.90.
Cheryl Young must pay $4,034.90 in costs allowed by the Clerk; the Secretary of Transportation remains entitled to those taxed costs.
What happened
In Young v. Buttigieg, Cheryl Young challenged costs assessed after the Secretary of Transportation won summary judgment on her remaining claims. The Clerk disallowed $3,800 of the Secretary’s requested costs and allowed $4,034.90.
Young argued that the costs should be reduced or eliminated because the case was important, the issues were difficult, costs could discourage similar cases, and she had limited resources. The court rejected those arguments, finding that the case was not unusually important or close and that Young had not shown that paying the allowed amount would impose an unjust burden.
Judge Spero denied Young’s motion to set aside the Clerk’s determination and ordered her to pay the $4,034.90 in costs taxed by the Clerk.
The detailed version
- Young v. Chao · No. 3:19-cv-01411
- Joseph Spero
- Feb. 14, 2023
Background
Cheryl Young, representing herself, brought claims challenging an Equal Employment Opportunity Commission decision and raising other claims about her employment at the Department of Transportation. The parties agreed to dismiss Young’s request for a new review of the agency decision and the Secretary of Transportation’s related counterclaims. The Secretary then won summary judgment on Young’s remaining claims.
The Secretary requested $7,834.90 in costs. The Clerk disallowed $3,800 and allowed $4,034.90. Young moved for review of the Clerk’s decision. The Secretary did not ask the court to review the costs the Clerk had disallowed.
Legal standard
Federal Rule of Civil Procedure 54(d)(1) generally creates a strong presumption that the prevailing party will receive taxable costs. A court may refuse or reduce those costs, but the losing party must show why awarding them would be inappropriate or unfair. Relevant considerations can include the case’s public importance, the closeness and difficulty of the issues, possible chilling effects on similar lawsuits, the plaintiff’s financial resources, and the parties’ economic disparity.
Court’s analysis
The court rejected Young’s argument that the case had unusual public importance. Although employment-discrimination cases can be important, Young did not show that this case had consequences beyond the parties or was substantially more important than a typical employment-discrimination case.
The court also found that the issues were not especially close or difficult. The Secretary had prevailed on summary judgment on all claims Young pursued, and the court described the grounds for that ruling as relatively straightforward. The dismissal of the counterclaims did not show that Young had obtained a separate litigation success because those counterclaims were tied to her dismissed request for a new review.
The court did not find a distinct chilling effect. The parties had withdrawn the claims and counterclaims connected to that review before the Secretary sought summary judgment, so Young’s agency award was no longer at risk. The court also found that Young had shown limited retirement income but had not provided evidence about her assets. Because she had previously represented that she could satisfy a judgment of more than $100,000, the court concluded that paying $4,034.90 would not make her indigent or otherwise impose an unjust burden. Finally, the court concluded that the government’s greater resources did not, by itself, justify refusing to award costs.
Disposition
Judge Joseph C. Spero denied Young’s motion to set aside the Clerk’s determination of costs. The court ordered Young to pay the $4,034.90 in costs taxed by the Clerk.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.