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Kelley V Bmo Harris Bank Na As Successor To Mi Marshall And Iisley

                 UNITED STATES DISTRICT COURT                            
                    DISTRICT OF MINNESOTA                                


Douglas  A. Kelley,  in  his  capacity  as  the         File No. 19-cv-1756 (ECT) 
Trustee of the BMO litigation trust,                                      

         Plaintiff,                                                      

v.                                       OPINION AND ORDER                

BMO Harris Bank N.A., as successor to                                     
M&I Marshall and Ilsley Bank,                                             

         Defendant.                                                      
________________________________________________________________________  
J. David Jackson, Dorsey & Whitney LLP, Minneapolis, MN; Joseph W. Anthony, Joseph 
Robert Richie, and Ryan Matthew Lawrence, Anthony Ostlund Baer & Louwagie PA, 
Minneapolis,  MN;    Michael  A.  Collyard,  Stephen  P.  Safranski,  Thomas  L.  Hamlin, 
William E. Manske, Michael D. Reif, and Peter Ihrig, Robins Kaplan LLP, Minneapolis, 
MN; and David  Marder and Morgia Holmes, Robins Kaplan LLP, Boston, MA, for 
Plaintiff Douglas A. Kelley in his capacity as the Trustee of the BMO Litigation Trust. 
Keith S. Moheban, Stinson Leonard Street LLP, Minneapolis, MN; Debra L. Bogo-Ernst, 
Joshua D. Yount, Lucia Nale, Thomas Vangel Panoff, and Gina Parlovecchio, Mayer 
Brown LLP, Chicago, IL; Donald B. Verrilli, Jr. and Elaine Goldenberg, Munger, Tolles 
& Olson LLP, Washington, D.C.; Christopher Steven Comstock, Sheppard Mullin Richter 
& Hampton LLP, Chicago, IL; Andrew J. Calica, Gina Parlovecchio, and Richard A. 
Spehr, Mayer Brown LLP, New York, NY; John Gleeson, Morgan A. Davis, Noelle E. 
Lyle, Susan Reagan Gittes, and Michael Schaper, Debevoise & Plimpton LLP, New York, 
NY; and Sean O’Donnell Bosack, Godfrey & Kahn, S.C., Milwaukee, WI, for Defendant 
BMO Harris Bank N.A., as successor to M&I Marshall and Ilsley Bank.       
________________________________________________________________________  
    Plaintiff Trustee Douglas A. Kelley alleged that Defendant BMO Harris Bank N.A., 
as successor-in-interest to M&I Marshall and Ilsley Bank, aided and abetted a breach of 
fiduciary duty committed by the management of Petters Company, Inc. (or “PCI”).  A jury 
returned a verdict in the Trustee’s favor and awarded more than $500 million in damages.  
The Eighth Circuit reversed and “remanded with directions to enter judgment in favor of 
BMO.”  Kelley v. BMO Harris Bank Nat’l Ass’n, 115 F.4th 901, 907–08 (8th Cir. 2024).  

The court held that the equitable defense of in pari delicto, as understood and applied by 
the Minnesota Supreme Court, barred the Trustee’s action against BMO because, even if 
BMO aided the scheme to the degree proven at trial, it “cannot be more culpable than the 
entity that orchestrated the scheme.”  Id. at 907.                        
    After the Eighth Circuit reversed and remanded, BMO filed two bills of costs.  
ECF Nos. 502, 505.  The first bill of costs, filed under Federal Rule of Appellate Procedure 

39(e), sought $3,092,267.21 in appellate bond premiums, $19,087.50 in fees for transcripts 
obtained for the appeal, and $1,010.00 in fees of the Eighth Circuit Clerk of Court, or a 
total of $3,112,364.71.  ECF No. 502 at 1.  With respect to BMO’s first bill of costs, the 
Clerk taxed $3,109,808.26 against the Trustee—nearly the full request, with a reduction in 
just the requested transcript fees.  ECF Nos. 511, 511-1.  The second bill of costs, filed 

under Federal Rule of Civil Procedure 54(d) and District of Minnesota Local Rule 54.3(c), 
sought $23,287.82  in  district-court  costs,  ECF  No. 505  at  1,  and  the  Clerk  allowed 
$16,563.09, ECF No. 512 at 1.                                             
    The Trustee seeks review of the Clerk’s cost judgments.  ECF No. 513; see D. Minn. 
LR 54.3(c)(3).  The Trustee raises two issues.  (1) He argues that appellate bond premiums 

are not taxable costs as a matter of law.  (2) He argues that awarding district court costs 
would be inequitable in view of BMO’s litigation conduct.  These issues will be considered 
in that order.                                                            
    (1) The appellate-bond-premium issue arises from a lack of correlation between a 
statute and a Federal Rule of Appellate Procedure.  The statute, 28 U.S.C. § 1920, identifies 

“[t]he costs that may be awarded to prevailing parties in lawsuits brought in federal court.”  
Taniguchi v. Kan Pac. Saipan, Ltd., 566 U.S. 560, 562 (2012).  Appellate bond premiums 
are not among the costs set forth in § 1920.  The Federal Rule of Appellate Procedure, on 
the other hand, says that “premiums paid for a bond or other security to preserve rights 
pending appeal” “are taxable in the district court for the benefit of the party entitled to costs 
under this rule.”  Fed. R. App. P. 39(e).  And the Rule makes clear that, “if a judgment is 

reversed, costs are taxed against the appellee.”  Fed. R. App. P. 39(a)(3).  The question is 
whether the omission of appellate bond premiums from § 1920 means these costs cannot 
be taxed notwithstanding Rule 39.                                         
    Courts addressing this question directly have held that appellate bond premiums are 
costs a district court may tax.  See, e.g., Campbell v. Rainbow City, 209 F. App’x 873, 876 

(11th Cir. 2006); Republic Tobacco Co. v N. Atl. Trading Co., 481 F.3d 442, 448 (7th Cir. 
2007); Berkley Reg’l Ins. Co. v. Phila. Indem. Ins. Co., 600 F. App’x 230, 237 (5th Cir. 
2015); In re RealNetworks, Inc., Nos. 09 Civ. 7760 (DLC), 41 Civ. 1395 (DLC), 2011 WL 
1642767, at *2 (S.D.N.Y. Apr. 29, 2011); Ericsson Inc. v. TCL Commc’n Tech. Holdings, 
Ltd., No. 2:15-cv-00011-RSP, 2020 WL 3469220, at *5–6 (E.D. Tex. June 23, 2020); 

Eshelman  v.  Puma  Biotechnology,  Inc.,  No  7:16-CV-18-D,  2022 WL  989743,  at  *4 
(E.D.N.C. Mar. 11, 2022).  A concise explanation for this holding appears in Republic 
Tobacco Co.  There, the Seventh Circuit, responding to an argument by the losing party 
(NATC), explained why the absence of appellate bond premiums from § 1920 did not 
prevent their recovery under Rule 39:                                     

         NATC is correct, as one of the Advisory Committee Notes to      
         Rule  39  mentions,  that  §  1920  provides  courts  with  the 
         authority to award costs under Rule 39.  NATC is also correct   
         that § 1920’s categories do not include one that allows costs for 
         bond premiums.  Nevertheless, Congress approved Rule 39         
         after it passed § 1920, and Rule 39 specifically provides that a 
         district court may award “premiums paid for a supersedeas       
         bond or other bond to preserve rights pending appeal.”  Where   
         the Federal Rules conflict with a “procedure provided in an     
         earlier act of Congress,” the Federal Rules control.  Am. Fed’n 
         of Musicians v. Stein, 213 F.2d 679, 686 (6th Cir. 1954); see   
         also 28 U.S.C. § 2072 (allowing the United States Supreme       
         Court to promulgate rules of procedure and declaring invalid    
         any laws that conflict with those rules at the time the rules take 
         effect).  In short, because Rule 39(e) expressly authorizes the 
         taxation of supersedeas bond costs, it is binding on district   
         courts regardless of whether § 1920 authorizes an award of      
         those costs.                                                    

Republic Tobacco Co., 481 F.3d at 448.                                    
    Though the Eighth Circuit has not discussed this question, it has affirmed a district 
court order taxing appellate bond premiums.  See Emmenegger v. Bull Moose Tube Co., 
324 F.3d 616, 626–27 (8th Cir. 2003); cf. Reeder-Simco GMC, Inc. v. Volvo GM Heavy 
Truck Corp., 497 F.3d 805, 808 (8th Cir. 2007) (affirming district court decision not to tax 
appellate bond premiums because prevailing party failed to file a bill of costs in the court 
of appeals).  And courts in this district and other districts within the Eighth Circuit have 
taxed appellate bond premiums.  See, e.g., Great Lakes Gas Transmission Ltd. P’ship v. 
Essar Steel Minn., LLC, No. 09-cv-3037 (SRN/LIB), 2017 WL 3025848, at *2 (D. Minn. 
July 17, 2017); St. John’s Mercy Med. Ctr. v. Delfino, No. 4:02CV01527 ERW, 2006 WL 
5363180, at *5 (E.D. Mo. Mar. 29, 2006).                                  

    The Trustee cites two cases to support his position that their omission from § 1920 
makes appellate bond premiums non-taxable, but these cases don’t carry weight on the 
issue.  The first is City of San Antonio v. Hotels.com, L.P., 593 U.S. 330 (2021).  There, in 
a footnote, the Supreme Court acknowledged that appellate “bond premiums, despite being 
referenced in Appellate Rule 39(e)(3), are not listed as taxable costs in § 1920.”  Id. at 341 
n.4.  The Court, however, declined to consider the question because it had not been raised 

by the losing party.  Id.  It would be a mistake to cite, as authority for holding that appellate 
bond premiums  are not taxable costs, a case that expressly declined to consider the 
question.  The second case the Trustee cites is Winniczek v. Nagelberg, 400 F.3d 503 (7th 
Cir. 2005) (per curiam).  There, the court wrote that Rule 39(e) did not “attempt to broaden 
the list of taxable items that appears in section 1920.”  Id. at 504.  Winniczek did not address 

appellate bond premiums; it addressed whether an appellate court’s docketing fee is 
taxable.  See id.  Regardless, the Seventh Circuit subsequently characterized the quoted 
sentence as dicta, and explained, “any suggestion in Winniczek’s dicta that Rule 39(e) does 
not expand the costs taxable under § 1920 is an over-reading” of the case.  Republic 
Tobacco Co., 481 F.3d at 448.  Against the seemingly unanimous weight of persuasive 

authority and the Eighth Circuit’s affirmance of a district court order taxing appellate bond 
premiums, it would be a mistake to adopt the Trustee’s position.          
    (2) “When an expense is taxable as a cost . . . there is a strong presumption that a 
prevailing party shall recover it ‘in full measure.’”  Concord Boat Corp. v. Brunswick 
Corp., 309 F.3d 494, 498 (8th Cir. 2002) (quoting In re Paoli R.R. Yard PCB Litig., 221 
F.3d 449, 468 (3d Cir. 2000)).  That presumption is codified in Rule 54(d).  The rule 

provides that “[u]nless a federal statute, these rules, or a court order provides otherwise, 
costs—other than attorney’s fees—should be allowed to the prevailing party.”  Fed. R. Civ. 
P. 54(d)(1); see Greaser v. Mo. Dep’t of Corr., 145 F.3d 979, 985 (8th Cir. 1998).  Despite 
the presumption, “[a] district court has ‘substantial discretion’ when determining an award 
of costs to a prevailing party under § 1920 and Rule 54(d).”  Dunne v. Res. Converting, 
LLC, 991 F.3d 931, 941 (8th Cir. 2021) (quoting Richmond v. Southwire Co., 980 F.2d 

518, 520 (8th Cir. 1992)).  The Eighth Circuit has affirmed cost reductions when “the case 
was over-litigated,” id. at 942, and when a party obtained only a nominal victory, see 
Richmond, 980 F.2d at 520; Grisso v. Massanari, 22 F. App’x 656, 658 (8th Cir. 2001), 
and other courts have determined that a party’s spoliation of evidence or other misconduct 
justified the denial of costs, see Nelson v. Thurston County, No. 3:18-cv-05184-DGE, 2023 

WL 8370156, at *3 (W.D. Wash. Dec. 4, 2023) (spoliation); Congregation of the Passion, 
Holy Cross Province v. Touche, Ross & Co., 854 F.2d 219, 222 (7th Cir. 1988) (“Generally, 
only misconduct by the prevailing party worthy of a penalty . . . or the losing party’s 
inability to pay will suffice to justify denying costs.”).  “The ‘losing party bears the burden 
of making the showing that an award is inequitable under the circumstances.’”  Concord 

Boat Corp., 309 F.3d at 498 (quoting In re Paoli, 221 F.3d at 462–63).    
    The Trustee argues that it would be inequitable to tax BMO’s district court costs 
against the Trustee because of BMO’s district court litigation conduct, but this contention 
is unconvincing on this case’s extensive record.  It is true that the Bankruptcy Court 
imposed  spoliation  sanctions  against  BMO,  see  ECF  No.  15-19  at  44  (granting  an 
adverse-inference instruction), and the district court affirmed this ruling, see ECF No. 125 

at 28.  But there is a weightier counterbalance against inequity the Trustee suffered because 
of the spoliation issue.  BMO moved to dismiss the adversary proceeding in the Bankruptcy 
Court in October 2016, relying on the in pari delicto doctrine.  See ECF No. 3-12 at 30–
48.  The argument was rejected and the motion denied (in relevant part).  See ECF No. 4-13 
at 11–13.  Under the Eighth Circuit’s ruling, the proceeding should have been dismissed 
on that ground at that time, meaning BMO should not have incurred taxable costs (or other, 

non-taxable costs and attorneys’ fees) in the district court.  In these circumstances, the 
district court cost judgment is not inequitable.                          
    The Trustee has a fallback position, but it doesn’t change things.  He claims that 
BMO  inequitably  “sought  transcript  costs  for  discovery  hearings  necessitated  by  its 
spoliation of evidence.”  ECF No. 515 at 14.  The Trustee does not identify how much of 

the $7,059.40 in transcript fees awarded to BMO were attributable to those hearings.  See 
ECF No. 512-1 at 1.  The absence of this information makes it impracticable to consider 
reducing these fees.  Accepting as true the Trustee’s claim that BMO sought “fees for 
witnesses—like  John  Vanderheyden,  Paul  Stroble,  and  David  Grant—whom  BMO 
proffered solely in an effort to excuse and minimize its intentional spoliation,” ECF No. 

515 at 14–15, the Clerk did not award transcript fees for any of these witnesses.  The Clerk 
taxed no costs for Stroble or Grant.  See ECF No. 512-1 at 2 (citing “[i]nsufficient 
documentation” for Stroble and explaining that Grant did not testify).  The Clerk taxed 
costs for Vanderheyden’s hotel stay in the amount of $375.66.  ECF No. 512-1 at 3; see 
ECF No. 505-4 at 12–13.  The Trustee did not target this amount in his motion.  If he had, 
the  same  considerations  discussed  in  the  preceding  paragraph  would  have  warranted 

rejecting the challenge.                                                  
                            ORDER                                        
    Based on the foregoing, and on all the files, records, and proceedings herein, IT IS 
ORDERED THAT:                                                             
    1.    Plaintiff Douglas A. Kelley’s Motion to Review Clerk’s Taxation of Costs 
[ECF No. 513] is DENIED.                                                  

    2.   The Clerk’s Cost Judgments in the amount of $3,109,808.26 [ECF No. 511] 
and $16,563.09 [ECF No. 512] for Defendant BMO Harris Bank N.A. are AFFIRMED. 

Dated:  July 22, 2025              s/ Eric C. Tostrud                     
                                  Eric C. Tostrud                        
                                  United States District Court