Daniellle Parker v. Comcast Cable Communications Management, LLC, 3:15-cv-05673

Plaintiff Danielle Parker, a former Comcast sales consultant, sued for disability discrimination after her May 2013 termination.
The district court granted summary judgment to Comcast, concluding Parker failed to establish a prima facie discrimination case; judgment entered May 25, 2017.
Comcast filed a bill of costs seeking $9,028.16 on June 6, 2017.
Parker opposed the bill, arguing she is indigent and urging denial or reduction of costs; she submitted a declaration describing severe financial hardship (unemployed, single mother, indebted, behind on rent).
The Court considered whether awarding costs would be unjust under Rule 54(d)(1) and Ninth Circuit factors and exercised its discretion to deny costs.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether prevailing party should be awarded costs under Rule 54(d)(1)	Parker argued costs should be denied because she is indigent and unable to pay, and awarding costs would be unjust and chill disability claims	Comcast sought costs as the prevailing party under the presumptive rule in Rule 54(d)(1)	Court declined to award costs, exercising discretion to deny them as unjust
Whether plaintiff's limited financial resources justify denying costs	Parker asserted extreme financial hardship (no income, single mother, debt, behind on rent)	Comcast argued prevailing-party presumption should apply absent strong justification	Court found Parker’s financial situation sufficient to overcome presumption and justify denial
Whether chilling effect on future civil-rights/disability litigants warrants denying costs	Parker contended imposing costs on an indigent disability plaintiff would deter future claims	Comcast did not meaningfully contest the chilling-effect argument	Court agreed denying costs helps avoid chilling disability litigation and weighed this factor for Parker
Whether litigation conduct and merits support denial of costs	Parker maintained she litigated in good faith, followed procedures, and had a sincerely held claim	Comcast relied on the merits-based summary judgment win to justify costs	Court found Parker litigated in good faith and that factor supported denying costs

Association of Mexican–American Educators v. State of California, 231 F.3d 572 (9th Cir.) (district courts must state reasons when refusing to award costs and presumption favors prevailing party)
Champion Produce, Inc. v. Ruby Robinson Co., Inc., 342 F.3d 1016 (9th Cir.) (enumerates factors courts may consider in denying costs)
Quan v. Computer Sciences Corp., 623 F.3d 870 (9th Cir.) (discussion of factors relevant to awarding or denying costs)