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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 (Target) (defendant) for wrongfully terminating her on the basis of gender. In its defense, Target claimed that Teague failed to mitigate. Teague claimed that after being fired by Target, she used her home computer to look for a new job and submit job applications online. She also sent and received email on this computer about her termination from Target. Teague claimed that she threw away her home computer about one year after hiring a lawyer to bring the suit against Target because the computer was broken. Target argued that Teague throwing away the computer was spoliation of electronic evidence. Target moved for the court to sanction Teague by dismissing her claim for back pay. The court held that sanctions of dismissal should only be imposed for spoliation when there has been bad faith conduct. Instead, the court sanctioned Teague for spoliation of evidence by issuing an adverse inference jury instruction (meaning that the judge told the jury that it may infer that Teague threw the computer away because it contained evidence that would hurt her claim). Target’s motion to have the court sanction Teague was granted in part and denied in part.

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Holding and Reasoning (Mullen, J.)

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