Michael David Barrett claimed he's virtually penniless and shouldn't have to foot the bill for a third party.
A California district court agreed, claiming ESPN voluntarily paid all the expenses on behalf of Andrews and finding restitution inappropriate.
Andrews said she's disappointed with the decision.
"In my mind Barrett should pay for all the trouble and expense he and he alone caused," Andrews said, according to TMZ.com.
Barrett was convicted in March to 2.5 years in prison for stalking Andrews and shooting nude videos of her through a hotel room peephole.