Walls v. Lee Memorial Health System
2:23-cv-00150
M.D. Fla.Apr 14, 2025Background
- Plaintiff Jennifer L. Walls sued Lee Memorial Health System and lost; summary judgment was granted to the defendant.
- The defendant, as the prevailing party, sought to recover specific costs totaling $8,655.14, which the Clerk taxed against Walls.
- Walls filed a motion challenging several categories and amounts of taxed costs and, based on her financial hardship, asked the court to deny them entirely.
- The court reviewed the taxed costs as requested, evaluating each category against statutory requirements.
- The court considered but ultimately rejected Walls’ request to deny all costs solely on her financial condition due to insufficient documentation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Taxing costs in general | Costs should be reduced or eliminated; no costs at all due to her finances | As prevailing party, entitled to full requested costs | Reviewed and reduced some costs; denied total denial of costs |
| Service/subpoena costs | No explicit objection; implied as part of total costs challenge | These were necessary for case (medical records) | Allowed; costs were reasonable and necessary |
| Transcripts and deposition fees | Some deposition-related overhead (e.g., amenities, virtual) should be excluded | All such expenses are proper | Reduced: eliminated overhead/amenity charges |
| Witness and mediation fees | General objection to witness fees; mediation costs not taxable | Sought full reimbursement | Only $40 witness fee allowed; mediation costs excluded |
| Financial hardship as bar | Plaintiff’s limited income and obligations justify denying all costs | No basis to deny costs; financial hardship insufficient | Financial hardship not sufficiently documented; costs allowed |
Key Cases Cited
- Fireman’s Fund Ins. Co. v. Tropical Shipping & Constr. Co., 254 F.3d 987 (11th Cir. 2001) (Prevailing party presumptively entitled to costs under Rule 54(d)).
- U.S. E.E.O.C. v. W&O, Inc., 213 F.3d 600 (11th Cir. 2000) (Costs must be limited to those authorized by statute; sets guidance on taxable costs).
- Chapman v. AI Transp., 229 F.3d 1012 (11th Cir. 2000) (District court discretion on costs is limited and must state sound basis).
- Duckworth v. Whisenant, 97 F.3d 1393 (11th Cir. 1996) (Non-recoverability of certain overhead deposition costs).
- Crawford Fitting Co. v. J.T. Gibbons, Inc., 482 U.S. 437 (1987) (Limits expert witness reimbursement to statutory amounts).