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Case shelved under Reasonableness
No Prejudice, No Spoliation Sanction
Archer et. al. v. York City School District, et. al.
M.D. Pa. December 28, 2016
Why This Case Is Important
Under new FRCP Rule 37(e), prejudice is required to warrant spoliation sanctions. With no proof of prejudice, there are no spoliation sanctions.
Overview:
In response to the plaintiffs’ legal claims that were in protest of the defendant’s decision not renew their school’s charter, the defendant motioned for summary judgment. The plaintiff claimed within their response to this motion that the defendant spoliated relevant data, i.e. the deletion of a key custodian’s email account.
The key issue in this case was whether the email account was deleted with prejudice.
The defendant contends that the email account was probably deleted within 90 days of the key custodian’s departure in February 2012, which would be in accordance with the defendant’s general practice. The plaintiffs’ argue that the key custodian’s emails were “purged sometime after 2012.”
Ruling:
- No “Factual Basis” to Support Prejudice. The court quoted the 3rd Circuit, stating “although a District Court has discretion to draw inferences from the record on a party’s intent, it strays beyond the bounds of its discretion when…there is no factual basis to do so.” The plaintiffs offered no evidence showing the defendants intended to destroy evidence that would be helpful to the plaintiffs’ case.
- Defendant Justifies Email Account Deletion. The defendant purged the key custodian’s email account within 90 days of her departure, and litigation did not commence until a year after the deletion occurred, supporting the notion that defendant had no intent to deprive.
- No Duty to Preserve. Additionally, the court found the defendant was under no duty to preserve the key custodian’s email account since litigation was not reasonably foreseeable when the deletion occurred.
Download Case Law Analysis PDF
Download the PDF version of Archer et. al. v. York City School District. et. al. case analysis here.
relevant resource
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