Manansingh v. United States, 2:20-cv-01139

Plaintiffs Chandan Manansingh and Angela Nairns brought suit against the United States and several federal probation officers, arising from a 2016 probationary search of their residence and a subsequent indictment.
Claims included constitutional causes of action under Bivens and state law tort claims under the Federal Tort Claims Act (FTCA).
The case proceeded to a bench trial in May 2025, after which judgment was entered in favor of the United States.
The United States, as prevailing party, then sought $8,308.85 in taxable costs from Plaintiffs.
Plaintiffs objected to the award and amount of costs, particularly the deposition transcript fees.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether costs should be awarded given the nature of the claims and parties	Costs should not be awarded as the case raised important constitutional rights and Plaintiffs have fewer resources.	Costs should be awarded to the prevailing party under Rule 54(d).	Costs awarded; factors did not justify denying them.
Whether the requested deposition transcript fees were recoverable	Only Manansingh’s deposition, used at trial/summary judgment, is recoverable.	All were part of discovery; all are recoverable under local rules.	Most deposition costs allowed; limited reduction for certain administrative charges.
Whether printing costs were recoverable	No objection to reasonable printing costs.	Printing of exhibit binders for trial should be recoverable.	Printing costs allowed in full.
Whether the cost award would chill future civil rights actions	Award would deter similar cases and civil rights litigation.	No chilling effect given factual history and the parties' resources.	No chilling effect; costs awarded.

Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics, 403 U.S. 388 (1971) (recognizing private cause of action for constitutional violations by federal agents)
Draper v. Rosario, 836 F.3d 1072 (9th Cir. 2016) (articulating factors for denying costs to prevailing party)