Lorie Applebaum v. Target Corporation

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that Rule 37(e)(2) requires the plaintiff to show intent
• plaintiff offered no evidence some of the records existed, much less defendant destroyed them with a culpable state of mind
• “It bears adding that to the extent Applebaum sought an adverse inference instruction for spoliation of electronic information, a 2015 amendment to Civil Rule 37(e)(2
• “A showing of negligence or even gross negligence will not do the trick.”

Source: CourtListener parenthetical corpus (CC0).