Judge: Mark H. Epstein, Case: BC705877, Date: 2023-12-01 Tentative Ruling
Case Number: BC705877 Hearing Date: December 1, 2023 Dept: I
This is a motion to tax costs. Following a jury trial, the jury entered
judgment in plaintiff’s favor. Plaintiff
is entitled to costs as a prevailing party, and defendant does not contest as
much (although there are some items in dispute). But plaintiff also claims additional costs
under CCP section 998. Years ago,
plaintiff made a statutory offer of $100,000, which is less than the jury’s
ultimate verdict, which is reflected in the judgment. Defendant did not accept the offer. Defendant contends that the offer should be
disregarded because it was a bad faith offer given the state of play at the
time. More specifically, defendant notes
that at the time the offer was made, much of the damage plaintiff asserted at
trial in terms of medical procedures had not yet been incurred and there was no
good reason to assume that they ever would be incurred. Accordingly, while a $100,000 offer close to
trial might have been good faith, the offer in 2019 was not and the rejection
of it should not trigger additional costs under the statute.
The recovery of costs is purely statutory, and a prevailing party is entitled as a matter of right to recover costs of suit in any action or proceeding. (Code Civ. Proc., § 1032, subd. (b).) Statutorily allowable costs, however, must be “reasonably necessary to the conduct of the litigation” and “reasonable in amount.” (Code Civ. Proc., § 1033.5 subd. (c)(2), (3).) A verified memorandum of costs is prima facie evidence of its propriety. (Ladas v. California State Auto. Assn. (1993) 19 Cal.App.4th 761, 774.) The party opposing those costs must show they were not reasonable or necessary. (Ibid.) It is therefore the objecting party’s burden to show the costs were not legitimate. (Fennessy v. DeLeuw–Cather Corp. (1990) 218 Cal.App.3d 1192, 1195.) Section 998 allows certain additional costs to be recovered under certain circumstances.
The court turns first to
whether the 998 offer was reasonable when made.
Defendant asserts that plaintiff only had two epidural shots during that
time and there was no indication of future treatment. In reply, defendant emphasizes the claim that
plaintiff was gaming the system by sending the 998 offer when he did. The court must resolve that issue to
determine whether enhanced costs are available.
The test works as follows. “An
offering party who prevails on its offer bears the later burden of showing that
the offer was ‘valid’ under CCP section 998, meaning compliant with the statute
and ‘ “sufficiently specific to permit the recipient meaningfully to evaluate
it and make a reasoned decision whether to accept it, or reject it and bear the
risk [one] may have to shoulder [the] opponent's litigation costs and
expenses. [Citation.]” ’ (MacQuiddy v. Mercedes-Benz USA, LLC
(2015) 233 Cal.App.4th 1036, 1050; see Covert v. FCA USA, LLC (2022) 73
Cal.App.5th 821, 833.) Validity is
determined as of the date the offer was served.
(Covert, at p. 832.) [¶]
Once the validity of a CCP section 998 offer is established by the offeror, the
burden then shifts to the offeree to demonstrate that the offer was
unreasonable or not made in good faith.
(Covert, supra, 73 Cal.App.5th at p. 833.) If the actual judgment is more favorable to
the offeror than was the offer, it is prima facie evidence of the offer's
reasonableness. (Id. at pp.
833–834.) Whether an offer is made in
good faith is based on whether, at the time it was made, it carried a
reasonable prospect of acceptance by the offeree. (Id. at p. 834.) The court inquires: ‘ “First, was the [CCP
section] 998 offer within the ‘range of reasonably possible results’ at trial,
considering all of the information the offeror knew or reasonably should have known? [Citation.]
Second, did the offeror know that the offeree had sufficient
information, based on what the offeree knew or reasonably should have known, to
assess whether the ‘offer [was] a reasonable one,’ such that the offeree had a
‘fair opportunity to intelligently evaluate the offer’?” [Citations.]’
(Id. at p. 834.)” (Glassman
v. Safeco Ins. Co. of America (2023) 90 Cal.App.5th 1281, 1313–1314,
parallel citations omitted.) The theory
is easy to understand. The test is
designed to ensure that the offeree understands what it means to accept or
reject the offer; there can be no uncertainties. Thus, an offer to settle for $10,000 plus
future expenses if incurred would not suffice because it is too vague to be
analyzed and the offeror would fail to meet its burden. Similarly, an offer that expired in three
days would fail because the statute requires a longer period. On the other hand, an offer by defendant to
settle for $10.00 made along with the answer is generally invalid. True, it meets the technical requirements,
but no reasonable plaintiff would accept it under most circumstances. The purpose of the offer is not to settle the
case; it is to change the statutory costs that are recoverable. Because there is no real debate here as to
whether the 998 offer was valid when made (that is, it met the technical
statutory requirements), it is defendant’s burden to show that the offer was
unreasonable or made in bad faith. The
test is not a hindsight test. The court
does not look at whether the offer made sense at the time of trial; the court
looks to whether the offer made sense at the time it was made.
The 998 offer here was
reasonable at the time it was made. It
was made more than a year after the case was filed and while discovery was well
underway. Further, defendant had access
to evidence indicating that plaintiff’s treatment cost approximately $48,457.24
at that time. Plaintiff also testified
that he was still in pain and would consider additional treatment if it would
help with the pain. (Dollison Decl.,
¶¶4-7.) To the court, this indicates
that the 998 offer was within the reasonable range when made, given the cost of
the medical bills and the expressed potential need for future treatment. Defendant complains that there was a big gap
between these 2019 statements and when plaintiff sought more treatment. The court agrees that there was a big gap
between the 2019 statements and the time when plaintiff sought more treatment,
but that is not the test. The
information that defendant had at the time indicated that plaintiff’s
medical bills, as of 2019, were already approximately $50,000 and that he might
seek more treatment. And that was just
medical bills. Defendant ignores
quantifying the numbers for non-economic losses like pain and suffering. The deposition indicates that plaintiff
continued to suffer from pain. As such,
the $100,000 number seems reasonable in light of the evidence defendant had in
her possession on October 4, 2019. It
was a high number, to be sure, but not an unreasonably high one. The court also notes that one purpose of a
998 offer is that it limits and caps future risk. A physical injury often carries a risk of the
unknown. Things can get worse. (Of course, they can also get better, but
money already paid is water over the dam; the costs can only go up.) The offer was a willingness by plaintiff to
cap that risk. By rejecting the offer,
defendant elected to take that risk.
True, were the additional costs utterly and completely unforeseeable the
analysis would be harder, but that is not the case here. To be clear, the court is not saying that defendant
acted unreasonably in rejecting the offer.
A clear-eyed party could well do the math and decision-tree analysis and
reasonably conclude that as an economic matter it would be better to reject the
offer and take its chances as things go forward or at trial. But that is not the test or the question.
This necessarily means
that plaintiff is entitled to request post-offer expert fees and demand
pre-judgment interest from the date the offer expired. “If an offer made by a plaintiff is not
accepted and the defendant fails to obtain a more favorable judgment or award
in any action or proceeding other than an eminent domain action, the court or
arbitrator, in its discretion, may require the defendant to pay a reasonable
sum to cover postoffer costs of the services of expert witnesses, who are not
regular employees of any party, actually incurred and reasonably necessary in
either, or both, preparation for trial or arbitration, or during trial or
arbitration, of the case by the plaintiff, in addition to plaintiff's
costs.” (Code Civ. Proc., § 998, subd.
(d).) “If the plaintiff makes an offer
pursuant to Section 998 of the Code of Civil Procedure which the defendant does
not accept prior to trial or within 30 days, whichever occurs first, and the
plaintiff obtains a more favorable judgment, the judgment shall bear interest
at the legal rate of 10 percent per annum calculated from the date of the
plaintiff's first offer pursuant to Section 998 of the Code of Civil Procedure
which is exceeded by the judgment, and interest shall accrue until the
satisfaction of judgment.” (Civ. Code, §
3291.) In this case, the court believes
that expert fees are appropriate. The
point of the 998 offer is to avoid having to retain the expert and pay the
fees. Here, because the offer was
rejected, plaintiff had to incur the fees and costs. The court, in its discretion, will allow
recovery of those fees under section 998.
Prejudgment interest is not discretionary and thus is awarded. Were it discretionary, the court would award
such interest.
Turning to costs
recoverable under section 1033.5, defendant challenges: costs incurred prior to
October 4, 2019; mediation; DME nurse; lodging; subpoenae; and minute
orders. Defendant also claims that the
expert fees, even if recoverable, are excessive. The court turns next to the amount of the
expert fees. Plaintiff requests
$27,812.50 for his expert, Dr. George Rappard, and an additional $2,850 for
deposing defendant’s experts. On the
former cost, defendant asserts that only the $8,000 for trial was reasonable
based on Dr. Rappard’s trial testimony.
Defendant fails to establish that the Dr. Rappard fees are unreasonable
or unnecessary, and that is her burden.
Dr. Rappard testified on August 30.
He testified that his fee for his trial appearance was $8,000. But he also charged a retainer and for work
done on the case prior to trial (but after the 998 was rejected). This is reasonable for an expert
witness. The court does not believe that
section 998 limits the recovery to the fees incurred while the expert is
actually in the courtroom. Further,
deposing defendant’s experts is reasonable and necessary. Plaintiff needed to know what their testimony
would be in order to defend against their testimony at trial. Those costs are recoverable under section
998.
As to the remainder of the
fees, the court GRANTS the motion in part and DENIES the motion in part. The court GRANTS the motion as to the
mediation mediation costs of $4,250 (plaintiff paid $2,125 twice). Mediation is voluntary and so the fees cannot
be shifted onto defendant. The case upon
which defendant relies was not a voluntary mediation agreed upon by the
parties. Unless the parties also
stipulated that the mediation cost would be recoverable, it is not
recoverable. The mediation costs are
taxed.
Sending a DME nurse to a
medical examination in order to monitor how the exam is administered is
reasonable and necessary. This is done
to protect the client’s interests and have a basis to challenge the report if biased
or improper. The subpoenae are also
proper, as they were directed to anesthesiologists who were subpoenaed to
appear at the 2021 trial. The fact that
they were not called to the witness stand does not mean that subpoenaing them
was unreasonable. Trials are fluid
things. Some witnesses are under
subpoena but as the trial progresses, the party issuing the subpoena elects not
to call the witness. That does not mean
that the subpoena was unnecessary or improper.
The other 2021 subpoena fees are proper for the same reason. It is proper to subpoena witnesses, even if
they do not testify, as long as their testimony might have been necessary. (And as to 2021, the trial began and a
mistrial was declared. That problem can
hardly be laid at plaintiff’s door.) The
photocopy cost of the trial binders is also recoverable. Plaintiff placed the cost in the wrong
section, but it does not mean it is not recoverable. The statute permits recovery for photocopies
and these were binders for the case.
(See Code Civ. Proc., § 1033.5, subd. (a)(13).) The motion is DENIED as to these items.
The motion is GRANTED as
to defendant’s hotel costs. Plaintiff
offered to pay the cost. Having so
offered (for good and sufficient reason), plaintiff cannot now recover it. The hotel costs are taxed. While plaintiff argues that defendant
basically forced this issue by failing to stipulate to liability until the last
minute, that does not suddenly transform the cost into a reasonable or
necessary one.
Any cost set forth in the
motion not discussed above is proper in the court’s view, and the motion is
DENIED as to any such cost. The parties
are to meet and confer and agree upon the amount of the costs that will be
awarded based on the above order. They
will then submit an appropriate document to the court. Of course, agreeing on the number is not a
waiver of any appellate rights concerning any part of this order with which any
party disagrees; any such rights are preserved.