Even when court-ordered, mediation is not a recoverable cost in federal litigation under 28 U.S.C. § 1920. Fantroy v. Publix Super Markets, Inc., No. 8:12-cv-1940-T-33EAJ (U.S.D.C. M.D. Fla., February 3, 2014)
Mediation fees may not be imposed as costs on the losing party under local rule or practice in Montana. Lazy JC Ranch, LLC v. Donnes, No. DA 13-0249 (Mont., January 28, 2014)
