Rimkus Consulting Group, Inc. v. Cammarata
United States District Court for the Southern District of Texas
688 F. Supp. 2d 598 (S.D. Tex. 2010)
Nickie Cammarata and Gary Bell (defendants), former employees of Rimkus Consulting Group (plaintiff), left to form a competing company. After they sued Rimkus in Louisiana seeking to invalidate parts of their employment contracts, Rimkus sued them in Texas for breach of contract and trade-secret misappropriation; the cases were consolidated in federal court in Texas. The defendants admitted deleting relevant emails and allegedly discarded laptops to prevent recovery, adopting a policy of deleting emails after two weeks; Rimkus also accused them of lying under oath. Rimkus sought sanctions including monetary penalties, an adverse jury instruction, and default judgment.
Whether a federal court has authority to sanction a party for willfully destroying evidence relevant to litigation.