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Awarded Costs Constrained By Federal Rules And Regional Circuit Law

Client Alert | 1 min read | 02.09.06

In Summit Technology, Inc. v. Nidek Co., Ltd. (No. 05-1292; January 26, 2006), a Federal Circuit panel modifies the district court's award of costs, remanding the case to the lower court for entry of the modified award. At issue are the constraints of § 1920 of the Federal Rules of Civil Procedure dealing with taxation of specified costs, as applied under First Circuit law. The panel determines that video animations are not “exemplifications” as provided in 28 U.S.C. § 1920(4). Reviewing a variety of cases and Blacks Law Dictionary, which defines “exemplifications” as “[a]n official transcript of a public record, authenticated as true copy for use as evidence”, the panel determines that the First Circuit would adopt a narrow definition of “exemplifications” and refuse to allow recovery for video animations. The panel also reduces the lower court's award of photocopy and deposition costs as these portions of the award are not deemed properly supported by the evidentiary record.

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Client Alert | 4 min read | 03.05.26

DOL’s Proposed Independent Contractor Rule Reverts to Prioritize Two Core Factors – Likely Limiting Misclassification Claims by Contractors

The U.S. Department of Labor (DOL) has proposed another revision to independent contractor regulations, one that would provide for more leeway in classifying workers as contractors. DOL’s proposed rule, published on February 26, 2026, would rescind the Biden DOL’s March 2024 independent contractor regulation and reinstate a framework substantially tracking the prior Trump rule of January 2021. The proposed rule would also apply the narrower analysis to worker classifications under the Family and Medical Leave Act (FMLA) and the Migrant and Seasonal Agricultural Worker Protection Act (MSPA). The comment period closes in late April 2026; until then, the 2024 rule remains in effect for purposes of private litigation....

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