Whether federal courts may grant an adverse inference as a sanction for negligent spoliation of evidence

QUESTION PRESENTED FOR REVIEW Whether federal courts may grant an adverse inference as a sanction for negligent spoliation of evidence, as the Second, Sixth, and D.C. Circuits have held, or whether “bad faith” is the standard, as held by the Eleventh Circuit below, as well as the Third, Fifth, Seventh, Eighth, and Tenth Circuits. ii PARTIES AND