The city of Sarnia is arguing it should not have to pay any of River City Vineyard's costs in the court battle over its Mitton St. homeless shelter.
The deadline for submissions to the Ontario Court of Appeal was Thursday.
A settlement offer that would have seen the city assume $125,000 of the church's costs was rejected by city council by a vote of 4-3.
In its submission, made public Thursday, outside legal counsel says the city essentially had to go to court, in the public interest, after River City did not appeal to the Ontario Municipal Board and continued to operate the shelter after council had denied permanent rezoning.
The city also argues there is no evidence that River City lacks the funds to pay its legal costs and that, if the court decides some costs should be awarded, they should be fixed at $10,000.
Sarnia's own legal costs amount to over $168,000.
On July 3, the court of appeal overturned a lower court ruling that closed the shelter, saying the city's zoning bylaw had been misinterpreted.
The city has until September 30 to decide if it will seek leave to appeal to the Supreme Court of Canada.