Following dismissal of the plaintiff’s action and the unsuccessful appeal, the self-represented defendant sought costs totaling $12,093.30.
The court considered the governing principles for awarding costs to self-represented litigants, including the requirement that the litigant demonstrate time spent performing work ordinarily done by a lawyer and that the time represented an opportunity cost in lost income.
Applying the principles from Fong v. Chan and Mustang Investigations v. Ironside, the court allowed compensation for certain legal preparation activities but excluded time for travel and general attendance.
The court emphasized that costs principles apply equally to self-represented parties and that successful litigants may receive indemnification where opportunity cost is proven.
A reduced amount representing lost income and disbursements was awarded.
