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Loring Winn Williams sued his employer, the fire district, for disability discrimination under the California Fair Employment and Housing Act (“FEHA”). Williams v. Chino Valley Indep. Fire Dist.(2013)218 Cal. App. 4th 73. The fire district ultimately prevailed on a summary judgment motion against Williams. Thereafter, the court awarded $5,368.88 in costs to the fire district pursuant to Cal. Civ. Proc. Code §1032(b), which allows a prevailing party to recover costs in any action or proceeding.

Williams claimed that no costs should be awarded to the fire district because his discrimination claim was not “frivolous, unreasonable, or groundless.” Williams relied on the U.S. Supreme Court standard in Christianburg Garment Co. v. EEOC: “In sum, a district court may in its discretion award attorney's fees to a prevailing defendant in a Title VII case of action upon a finding that the plaintiff's action was frivolous, unreasonable, or without foundation, even though not brought in subjective bad faith.” Christiansburg Garment Co. v. EEOC (1978) 434 U.S. 412, 421.

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