Costs: Fifth District Agrees That Unity Of Interest Principle Was Repealed In The Routine Costs Area

It Endorsed The Reasoning In The Charton Opinion.

               In Mosley v. Pacifica Bakersfield, L.P., Case No. F084699 (5th Dist. Sept. 20, 2024) (unpublished), a co-defendant dismissed right before trial was awarded a little over $28,000 in routine costs against plaintiff, who won sizable damages.  The Fifth District affirmed, deciding that (1) CCP § 1032(a)(4) and (b) made the dismissed defendant a prevailing party, and (2) Charton, 247 Cal.App.4th 730, 734 correctly reasoned the “unity of interest” principle was repealed from the costs statute such that a lower court has no mandatory duty to apportion where multiple defendants are represented by the same counsel.

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