I came across an interesting case from my home state of Illinois in which the defendant, a public agency apparently destroyed documents in violation of state law and its own policy. The judge in this matter however ruled that this was not sufficient for sanctions which need to be matter specific.
See Dorrene Sokn, Plaintiff, v Fieldcrest Community Unit School District No. 8
http://jenner.com/system/assets/assets/7875/original/Sokn_20v._20Fieldcrest_20Community_20Unit_20School_20District_20No._208.pdf
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