Williams v. Chino Valley Independent Fire District
61 Cal. 4th 97
| Cal. | 2015Background
- Williams sued Chino Valley Independent Fire District for disability discrimination under FEHA.
- Trial court granted summary judgment for the District and awarded costs.
- Williams appealed the costs order.
- Issue: whether FEHA costs are mandatory under CCP 1032 or discretionary under Gov. Code 12965(b).
- Court held Gov. Code 12965(b) is an express exception and governs FEHA cost awards; discretion applies to both fees and costs.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| FEHA cost awards governed by CCP 1032 or Gov. Code 12965(b)? | Williams urged CCP 1032(b) entitlement as matter of right. | District urged 12965(b) discretionary control. | 12965(b) governs costs. |
| Does Christiansburg apply to FEHA costs for prevailing defendants? | Williams argues no; costs not subject to Christiansburg. | District argues Christiansburg standard should apply to FEHA costs. | Christiansburg applies to both attorney fees and costs; defendant must show groundlessness for costs. |
| Are prior Perez/Knight/Hatai dicta reconciled under FEHA cost discretion? | Perez lower court approach acceptable. | Knight/Hatai oppose applying Christiansburg to ordinary costs. | Perez/Knight/Hatai disapproved to the extent they deny Christiansburg for ordinary FEHA costs. |
Key Cases Cited
- Christiansburg Garment Co. v. EEOC, 434 U.S. 412 (Sup. Ct. 1978) (set forth objective-groundless standard for prevailing defendants in civil rights suits)
- Perez v. County of Santa Clara, 111 Cal.App.4th 671 (Cal. App. 2003) (held ordinary FEHA costs may be discretionary even without frivolous action finding (disapproved to extent inconsistent with Christiansburg))
- Knight v. Hayward Unified School Dist., 132 Cal.App.4th 121 (Cal. App. 2005) (followed Perez on FEHA costs duty not to disallow entirely; later disapproved for not applying Christiansburg standard)
- Chavez v. City of Los Angeles, 47 Cal.4th 970 (Cal. 2010) (harmonized FEHA/Codes; held FEHA remedies align withChristiansburg framework; discusses efficiency/fehe policy)
- Cummings v. Benco Building Services, 11 Cal.App.4th 1383 (Cal. App. 1992) (adopted Christiansburg standard for FEHA fee/cost awards to prevailing defendants)
- Brown v. Lucky Stores, Inc., 246 F.3d 1182 (9th Cir. 2001) (ADA costs/fees treated under Christiansburg; costs awarded under ADA precedent)
- Martin v. California Dept. of Veterans Affairs, 560 F.3d 1042 (9th Cir. 2009) (Rehabilitation Act; discusses costs/fees where parallel provisions exist with ADA; supports applying Christiansburg to costs)
- Davis v. KGO-TV, Inc., 17 Cal.4th 436 (Cal. 1998) (discussed costs/allowable costs; distinguishs scope from 12965(b) interaction; disapproved dictum on scope for FEHA costs)