Taniguchi v. Kan Pacific Saipan, Ltd.
132 S. Ct. 1997
| SCOTUS | 2012Background
- Taniguchi, a Japanese baseball player, sued Kan Pacific Saipan for injuries from a fall through a resort deck.
- During litigation, Kan Pacific paid for Japanese-to-English document translations to prepare its defense.
- After summary judgment for Kan Pacific, the district court taxed those translation costs as 'compensation of interpreters' under §1920(6).
- The Ninth Circuit affirmed, holding the term could include document translation as part of interpreter services.
- The Supreme Court held that 'interpreter' ordinarily means oral translators only and does not cover written-document translation under §1920(6).
- The case is remanded for proceedings consistent with this interpretation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does §1920(6) cover document translation costs? | Taniguchi argues the word 'interpreter' should be read to include translators of written documents. | Kan Pacific contends 'interpreter' includes both oral and written translation given broad dictionary senses. | No; interpreters refer to oral translation only. |
| What is the ordinary meaning of 'interpreter' in the Court Interpreters Act context? | Interpreter includes translators of written materials as a broad meaning. | Interpreter primarily means oral translator; context supports oral-only reading. | Ordinary meaning is oral translator; written translation not included. |
| Does Rule 54(d) affect the interpretation of §1920(6)? | Rule 54(d) suggests broad cost recovery consistent with oral and written translation. | Rule 54(d) is not a license to rewrite §1920(6) definitions. | Rule 54(d) does not override the ordinary meaning of 'interpreter' in §1920(6). |
| Should the statutory context or pre/post-enactment practice govern the meaning of 'interpreter'? | Court practice and context show interpreters include document translation. | Context indicates a focus on oral interpretation; historical practice does not redefine the term. | Context supports oral-translation meaning; no broad redefinition. |
Key Cases Cited
- Alyeska Pipeline Service Co. v. Wilderness Society, 421 U.S. 240 (1975) (rules on cost taxation under federal statutes and state-law practices)
- Crawford Fitting Co. v. J.T. Gibbons, Inc., 482 U.S. 437 (1987) (Rule 54(d) and §1920 interpretation; not a broad power to tax non-enumerated costs)
- BDT Prods., Inc. v. Lexmark Int'l, Inc., 405 F.3d 415 (6th Cir. 2005) (document translation costs debated under §1920(6))
- Extra Equipamentos E Exportação Ltda. v. Case Corp., 541 F.3d 719 (7th Cir. 2008) (document translation costs not taxable under §1920(6))
- In re Puerto Rico Electric Power Authority, 687 F.2d 501 (1st Cir. 1982) (recognizing translation costs may be reimbursable in some contexts)
- Quy v. Air Am., Inc., 667 F.2d 1059 (D.C. Cir. 1981) (translation costs debated under §1920(6))
- Studiengesellschaft Kohle mbH v. Eastman Kodak Co., 713 F.2d 128 (5th Cir. 1983) (translation-related cost allocations under §1920)