Culp v. Woods: Seventh Circuit Re-Affirms Broad Discretion in Mixed-Outcome Cost Awards and Clarifies N.D. Indiana Local Rule 56.1 Compliance

Introduction

On 20 June 2025 the U.S. Court of Appeals for the Seventh Circuit decided Carl & Roberta Culp v. Scott Caudill, et al. (Nos. 23-2397 & 23-2398), affirming the Northern District of Indiana’s judgment. The lawsuit arose from an August 2018 confrontation between Carl Culp, a double amputee experiencing a mental-health crisis, and Fort Wayne police officers Whitney Woods and Stevan Schulien. The Culps alleged numerous federal and state claims, including:

• § 1983 excessive-force violations of the Fourth and Fourteenth Amendments,
• Intentional and negligent infliction of emotional distress, assault, battery, and criminal mischief under Indiana law,
• Violations of Title II of the Americans with Disabilities Act (ADA) and § 504 of the Rehabilitation Act.

After partial summary judgment and a jury verdict, only Roberta Culp prevailed—receiving $1 in nominal damages on a battery claim against Officer Woods. The Culps appealed the adverse rulings; Woods and Schulien cross-appealed the district court’s decision to deny them costs. The Seventh Circuit’s opinion, authored by Judge Rovner, addresses three principal issues:

1. Whether Fort Wayne’s summary-judgment filings complied with Local Rule 56.1 despite placing the statement of undisputed facts in an appendix,
2. Whether the ADA/Rehabilitation Act claims could survive summary judgment, and
3. Whether the district court abused its discretion in refusing to tax costs in a mixed-outcome case.

Summary of the Judgment

The Court affirmed across the board:

• Local Rule 56.1: The defendants’ use of an appendix for their Statement of Undisputed Material Facts satisfied the then-current version of N.D. Indiana Local Rule 56.1(a). Consequently, summary judgment was not procedurally defective.
• ADA / Rehabilitation Act: Assuming arguendo that Title II applies to arrests, the evidence could not show deliberate indifference or failure to accommodate; thus summary judgment for Fort Wayne PD and Allen County SD was appropriate.
• Costs: In a case with split success—a $1 plaintiff verdict amid sweeping defense victories—the district court acted within its “especially broad” discretion to have each side bear its own costs.

Analysis

Precedents Cited

• King v. Hendricks County Commissioners, 954 F.3d 981 (7th Cir. 2020) – Provides framework for ADA/Rehabilitation Act claims during police encounters; court again postpones deciding whether Title II applies to arrests, assuming applicability for analytical purposes only.
• Lacy v. Cook County, 897 F.3d 847 (7th Cir. 2018) – Defines “deliberate indifference” (two-part test) as the standard for intentional discrimination under ADA/RA.
• Testa v. Village of Mundelein, 89 F.3d 443 (7th Cir. 1996); Baker v. Lindgren, 856 F.3d 498 (7th Cir. 2017); Gavoni v. Dobbs House, 164 F.3d 1071 (7th Cir. 1999) – Clarify that Rule 54(d) cost awards are discretionary in mixed-result litigation.
• Buckhannon Bd. & Care, 532 U.S. 598 (2001) – Even nominal damages confer “prevailing-party” status; cited to show why both sides could plausibly claim that label.
• District-court rulings (Hill v. Brink’s, Graves v. Job Works) confirming that Local Rule 56.1 permits facts statements in an appendix.

Legal Reasoning

1. Local Rule 56.1 Compliance
   The Rule’s text allowed the Statement of Material Facts to appear “in the brief or the brief’s appendix.” Because the defendants used the appendix route, the requirement for record citations was satisfied. The appellate panel underscored that the plaintiffs cited no authority compelling automatic denial of motions for minor rule deviations.
2. ADA / Rehabilitation Act Claims
   a. The panel, echoing King, sidestepped the unresolved doctrinal question—whether Title II governs arrests—because, even if it did, Carl Culp could not show:
   • (i) that the officers’ conduct was “by reason of” his disability, or
   • (ii) that he requested and was denied a reasonable accommodation.
   His refusal to exit the car stemmed from non-disability motives; his prosthetic legs were already wet; and the lone “we don’t want to beat a handicapped man” statement evidenced awareness, not discrimination.
3. Cost Award Discretion
   Federal Rule 54(d)(1) establishes a presumption in favor of costs for prevailing parties. Yet Seventh-Circuit precedent vests “especially broad” discretion in trial courts when results are mixed. Here, the district court reasonably deemed the $1 plaintiff verdict and defense victories sufficiently balanced to offset each other and require each side to bear its own costs.

Impact of the Decision

• Procedural Clarity: Litigants in the Northern District of Indiana now have explicit appellate confirmation that, under the pre-2023 version of Local Rule 56.1, a statement of undisputed facts in an appendix is acceptable. Future summary-judgment challenges based on citation format alone are unlikely to succeed.
• ADA Litigation Against Police: The Seventh Circuit again leaves the foundational question unresolved, but continues to apply a rigorous “but-for disability” and “deliberate-indifference” threshold. Plaintiffs must marshal concrete evidence of a requested accommodation or discriminatory intent.
• Cost Awards in Split Verdicts: The opinion fortifies district courts’ latitude to deny costs when each party enjoys partial success, even if the plaintiff’s victory is merely nominal. Defense counsel must therefore weigh the cost-benefit of post-verdict cost-taxation motions more carefully.

Complex Concepts Simplified

• Title II (ADA) vs. § 504 (Rehabilitation Act): Both prohibit disability-based discrimination by public entities; claims are “functionally identical” in litigation.
• Deliberate Indifference: A public entity knows harm to a protected right is likely and fails to act. It is the ADA/RA analog to “intentional discrimination.”
• Mixed-Outcome Case: Litigation where both sides win something (e.g., plaintiff gets nominal damages, defendant defeats major claims). Courts may deviate from the usual “winner gets costs” rule.
• Local Rule 56.1 Statement: A listing of material facts the movant claims are undisputed. The rule’s flexibility on where that list appears became central here.
• Nominal Damages: A token sum (often $1) acknowledging a legal wrong without significant harm. Still enough to make a party a “prevailing party.”

Conclusion

Culp v. Woods principally reinforces two procedural teachings: (1) summary-judgment movants may satisfy N.D. Indiana Local Rule 56.1 with a well-crafted appendix of undisputed facts, and (2) district courts possess wide discretion to deny costs when litigation ends in a stalemate of sorts. Substantively, the Seventh Circuit again postpones deciding whether Title II of the ADA applies to arrests, signaling that plaintiffs who cannot muster evidence of disability-based causation will fail even if the statute applies. Consequently, the opinion tightens the evidentiary screws on ADA claims arising from police encounters and gives trial courts considerable leeway in handling post-verdict cost petitions.