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Crawford Fitting Co. v. J.T. Gibbons, Inc.

482 U.S. 437 (1987)

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Crawford Fitting Co. v. J.T. Gibbons, Inc.

United States Supreme Court
482 U.S. 437 (1987)

  • Written by Sharon Feldman, JD

Facts

J.T. Gibbons, Inc. (Gibbons) (plaintiff) sued Crawford Fitting Company and others (collectively, Crawford) (defendants) for alleged antitrust violations. Crawford obtained a directed verdict and filed a bill of costs, seeking reimbursement from Gibbons of expert-witness fees and other litigation expenses. Expenses that could be taxed as costs were enumerated in 28 U.S.C. § 1920, and 28 U.S.C. § 1821(b) limited witness fees to $30 per day. The district court held that it had discretion under Federal Rule of Civil Procedure (Rule) 54(d) to grant witness fees that exceeded § 1821(b)’s limit. The Fifth Circuit reversed the fee award, holding that expert-witness fees were limited to the § 1821(b) amount. International Woodworkers of America (IWA) (plaintiff) sued Champion International (Champion) (defendant) for racial discrimination. The district court dismissed IWA’s claims but declined to require IWA to reimburse Champion for expert-witness fees that exceeded the $30-per-day limit. The Fifth Circuit affirmed. The United States Supreme Court granted certiorari and consolidated the cases. Crawford and Champion argued that Rule 54(d) gave federal courts the power to tax as costs expenses not specifically enumerated in § 1920.

Rule of Law

Issue

Holding and Reasoning (Rehnquist, C.J.)

Concurrence (Blackmun, J.)

Dissent (Marshall, J.)

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