Teague v. Target Corp.
United States District Court for the Western District of North Carolina
2007 WL 1041191 (W.D.N.C. 2007)
Teague (plaintiff) sued Target Corp. (defendant) for wrongful termination based on gender, and Target argued Teague had failed to mitigate her damages. Teague used her home computer after her termination to search and apply for jobs and to send and receive email about her firing, but she discarded the computer about a year after hiring a lawyer to sue Target, claiming it was broken. Target argued this was spoliation of electronic evidence and moved to have Teague's back-pay claim dismissed as a sanction.
Whether a court may sanction a party for discarding a computer containing evidence material to her own discrimination lawsuit, and if so, what sanction is appropriate absent bad faith.