Christiansburg Garment Co. v. Equal Emp't Opportunity Comm'n

Holding that for a defendant to recoup attorneys fees under § 706(k) of Title VII, a court must find that the plaintiff litigated his or her claim beyond the point where it became “frivolous, unreasonable, or groundless” or where plaintiff acted in bad faith

Williams v. Chino Valley Independent Fire District

Concluding rule that prevailing defendant may recover attorney fees only if the plaintiff's "action was objectively groundless" articulated in Christiansburg Garment Co. v. Equal Employment Opportunity Comm'n 434 U.S. 412, 421-422 applicable to costs

Murillo v. Fleetwood Enterprises, Inc

Holding the Act should be interpreted to support its remedial purpose

Westamerica Bank v. MBG Industries, Inc.

Finding a valid section 998 settlement when it resolved the complaint between the parties and not the cross-complaint between the same parties

Elrod v. Oregon Cummins Diesel, Inc.

In Elrod, the Court of Appeal held the trial court did not abuse its discretion in finding the section 998 offer was unreasonable.

Fortman v. Hemco, Inc.

Finding that "damages are excessive only where the recovery is so grossly disproportionate to the injury that the award may be presumed to have been the result of passion or prejudice"

Mesa Forest Prod., Inc. v. St. Paul Mercury Ins. Co.

In Mesa Forest Prods. v. St. Paul Mercury Ins. Co., 73 Cal. App. 4th 324 (Ct.App. 2d Dist. 1999), the primary case cited by Parsons in support of its position, the California Court of Appeals (an intermediate appellate court) addressed "whether, in determining if a plaintiff in a contract action has obtained a `judgment' more favorable than an offer to compromise (Code Civ. Proc., § 998), the trial court should take into account the defendant's postoffer payments on the debt."

Wear v. Calderon

Reversing an award of costs following a verdict in favor of defendant based on $1 pretrial settlement offer; " plaintiff may not reasonably be expected to accept a token or nominal offer from any defendant exposed to [a substantial] liability unless it is absolutely clear that no reasonable possibility exists that the defendant will be held liable"

Holman v. Altana Pharma Us, Inc.

Permitting expert witness fees awarded to prevailing FEHA defendant to be “scaled” to the parties' relative financial resources

Pineda v. Los Angeles Turf Club, Inc.

In Pineda, plaintiff brought a wrongful death action seeking $10 million against a racetrack and manufacturer of racing helmets for the death of a jockey at the starting gate.

Rule 5 - Serving and Filing Pleadings and Other Papers

Allowing service by filing papers with the court's electronic-filing system

Section 1013 - Requirements for service by mail

Section 1010.6 - Electronic service of document

Authorizing trial courts to adopt local rules permitting electronic filing of documents