L.A. County Superior Court Judge Ralph Dau issued the ruling.
Rizzo claimed he should be reimbursed for expenses by the city of Bell in fighting civil and criminal charges he conspired to defraud Bell out of money.
Rizzo is the subject of a civil case brought by the city of Bell. The L.A. District Attorney's Office has filed criminal proceedings against Rizzo.
Bell attorneys contend Rizzo lost any rights to legal fees when he left his job in 2010.
"There is no contract in Rizzo's 1996 contract stating that the city's promise to defend does or does not survive (Rizzo's) termination," Dau wrote in a page ruling. "(The) city had not convinced in the correctness of its position."
Rizzo is among eight former Bell city officials accused of bilking taxpayers out of about $5.5 million through hefty salaries, benefits and illicit loans of public money.
The city's civil claims against Rizzo include intentional misrepresentation and restitution of money allegedly wrongfully obtained. He has also sued the city on various grounds, including his claim for reimbursement of his legal costs. Defense attorneys filed a separate motion for dismissal of his indemnity claim on Dec. 20 and a hearing before Dau is scheduled June 27.
The city's claims against Rizzo, as well as the remainder of his causes of actions against the city, have been put on hold pending the outcome of the criminal proceedings.
City News Service contributed to this report.