CRC, Rule 8.278 Is More Constricted In Scope
Gigena v. Finch, Case No. C104947 (2d Dist. July 30, 2026) (unpublished) involved an appeal of appellate routine costs under CRC 8.278, with an in pro per litigant’s appellate costs request being significantly reduced at the trial court level. The Third District affirmed, but in doing so did note a distinction from appellate versus trial level costs: appellate costs are specifically delineated, and they can be awarded if reasonable. However, Rule 278(d) “does not generically provide for costs ‘reasonably necessary’ to conduct litigation as [CCP] section 1033.5 does. Rather it expressly limits recovery of costs to items listed within the rule, if those costs are reasonable.” (Slip Op., p. 7.)