Costs: Defendant Winning One Dollar In Heavily Contested Case Was The Prevailing Party With Net Monetary Recovery For Purposes Of Routine Costs Award

Loser Provided No Authority That Pre-Litigation Payments Could Be Factored Into The Costs Calculus.       

Young Man Deposits Dollar Bill at Bank Teller's Window
    

            Defendant in a heavily contested contract case won $1 on its contract claim against a non-prevailing party. That was enough to justify an award of routine costs of the defendant because it received a net monetary judgment, said the appellate court in John Russo Industrial Sheet Metal v. City of L.A. Dept. of Airports, Case Nos. A150652/A150654 (1^st Dist., Div. 5 Dec. 18, 2018) (unpublished). Loser provided no authority for the proposition that pre-litigation money received from defendant should somehow be factored into the routine costs “prevailing party” analysis.