adverse inference instruction (West Virginia) · Go Syfert
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adverse inference instruction in West Virginia

6 West Virginia opinions name it 1 courts 1999–2017 0 in the last five years

The cases below were cited by West Virginia courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (6)

CaseFollowedCited
State v. Osakalumigreen
wva · 1995 · cited in 1 West Virginia opinions naming this issue, 2017–2017
1 sentence

2017See State v. Osakalumi, 194 W.

11
McNeel v. Union Pacific R. Co.green
neb · 2008 · cited in 1 West Virginia opinions naming this issue, 2015–2015
2 sentences

2015Co., 276 Neb. 143, 156 , 753 N.W.2d 321, 332 (2008) (“In Nebraska, die proper remedy for [intentional] spoliation of evidence is an adverse inference instruction.”); State v. Davlin, 263 Neb. 283, 302 , 639 N.W.2d 631, 649 (2002) ("an instruction on the inference that may be drawn from spoliation of evidence is appropriate only where substantial evidence exists to support findings that the evidence had been in existence, in the possession or under the control of the party against whom the inference may be drawn; that -the evidence would'have been admissible at trial; and that the party respons

2015Co., 276 Neb. 143, 156 , 753 N.W.2d 321, 332 (2008) (“In Nebraska, die proper remedy for [intentional] spoliation of evidence is an adverse inference instruction.”); State v. Davlin, 263 Neb. 283, 302 , 639 N.W.2d 631, 649 (2002) ("an instruction on the inference that may be drawn from spoliation of evidence is appropriate only where substantial evidence exists to support findings that the evidence had been in existence, in the possession or under the control of the party against whom the inference may be drawn; that -the evidence would'have been admissible at trial; and that the party respons

11
State v. Davlingreen
neb · 2002 · cited in 1 West Virginia opinions naming this issue, 2015–2015
2 sentences

2015Co., 276 Neb. 143, 156 , 753 N.W.2d 321, 332 (2008) (“In Nebraska, die proper remedy for [intentional] spoliation of evidence is an adverse inference instruction.”); State v. Davlin, 263 Neb. 283, 302 , 639 N.W.2d 631, 649 (2002) ("an instruction on the inference that may be drawn from spoliation of evidence is appropriate only where substantial evidence exists to support findings that the evidence had been in existence, in the possession or under the control of the party against whom the inference may be drawn; that -the evidence would'have been admissible at trial; and that the party respons

2015Co., 276 Neb. 143, 156 , 753 N.W.2d 321, 332 (2008) (“In Nebraska, die proper remedy for [intentional] spoliation of evidence is an adverse inference instruction.”); State v. Davlin, 263 Neb. 283, 302 , 639 N.W.2d 631, 649 (2002) ("an instruction on the inference that may be drawn from spoliation of evidence is appropriate only where substantial evidence exists to support findings that the evidence had been in existence, in the possession or under the control of the party against whom the inference may be drawn; that -the evidence would'have been admissible at trial; and that the party respons

11
MOYERS BY AND THROUGH MOYERS v. Ford Motor Co.green
moed · 1996 · cited in 1 West Virginia opinions naming this issue, 1999–1999
1 sentence

1999Accord Moyers v. Ford Motor Co., 941 F.Supp. 883, 885 (E.D.Mo.1996); Shaffer v. RWP Group, Inc., 169 F.R.D. 19, 25 (E.D.N.Y.1996); Baliotis v. McNeil, 870 F.Supp. 1285, 1289 (M.D.Pa.1994); Anderson v. National R.R.

11
Baliotis v. McNeilgreen
pamd · 1994 · cited in 1 West Virginia opinions naming this issue, 1999–1999
1 sentence

1999Accord Moyers v. Ford Motor Co., 941 F.Supp. 883, 885 (E.D.Mo.1996); Shaffer v. RWP Group, Inc., 169 F.R.D. 19, 25 (E.D.N.Y.1996); Baliotis v. McNeil, 870 F.Supp. 1285, 1289 (M.D.Pa.1994); Anderson v. National R.R.

11
Shaffer v. RWP Group, Inc.green
nyed · 1996 · cited in 1 West Virginia opinions naming this issue, 1999–1999
1 sentence

1999Accord Moyers v. Ford Motor Co., 941 F.Supp. 883, 885 (E.D.Mo.1996); Shaffer v. RWP Group, Inc., 169 F.R.D. 19, 25 (E.D.N.Y.1996); Baliotis v. McNeil, 870 F.Supp. 1285, 1289 (M.D.Pa.1994); Anderson v. National R.R.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in West Virginia. Read the followed side critically anyway.

Also cited on this issue (4)

CaseCitedYears
Hannah v. Heeter green
wva · 2003
2 sentences

2007We later noted in Hannah v. Heeter, 213 W.Va. 704 , 584 S.E.2d 560 (2003), that an adverse inference instruction and sanctions attainable under the provisions of Rule 37 of the West Virginia Rules of Civil Procedure are the sole remedies for correcting the actions of a party who negligently fails in performing a duty of preserving relevant evidence.

2007We later noted in Hannah v. Heeter, 213 W.Va. 704 , 584 S.E.2d 560 (2003), that an adverse inference instruction and sanctions attainable under the provisions of Rule 37 of the West Virginia Rules of Civil Procedure are the sole remedies for correcting the actions of a party who negligently fails in performing a duty of preserving relevant evidence.

22007–2007
Tracy v. Cottrell green
wva · 1999
2 sentences

2007Id. at 371 , 524 S.E.2d at 887 .

2007Id. at 371 , 524 S.E.2d at 887 .

22007–2007
Shreve v. Warren Assoc., Inc. green
wva · 1987
2 sentences

2003“Rule 37 of the West Virginia Rules of Civil Procedure is designed to permit the use of sanctions against a party who refuses to comply with the discovery rules, i.e., Rules 26 through 36.” Syllabus Point 1, Shreve v. Warren Assoc., Inc., 177 W.Va. 600 , 355 S.E.2d 389 (1987).

2003“Rule 37 of the West Virginia Rules of Civil Procedure is designed to permit the use of sanctions against a party who refuses to comply with the discovery rules, i.e., Rules 26 through 36.” Syllabus Point 1, Shreve v. Warren Assoc., Inc., 177 W.Va. 600 , 355 S.E.2d 389 (1987).

12003–2003
Eric Esher Schmid v. Milwaukee Electric Tool Corporation Eric Schmid green
ca3 · 1994
2 sentences

1999Under one test, 6 adopted by the Third Circuit Court of Appeals in Schmid v. Milwaukee Electric Tool Corp., 13 F.3d 76 (3d Cir.1994), a trial court must perform the following analysis in making a determination of whether to give an adverse inference instruction or impose other sanctions on a party because of spoliation of evidence: (1) determine the degree of fault of the party who altered or destroyed the evidence; (2) determine the degree of prejudice suffered by the opposing party; and (3) determine the availability of a lesser sanction that will protect the opposing party’s rights and dete

1999Under one test, 6 adopted by the Third Circuit Court of Appeals in Schmid v. Milwaukee Electric Tool Corp., 13 F.3d 76 (3d Cir.1994), a trial court must perform the following analysis in making a determination of whether to give an adverse inference instruction or impose other sanctions on a party because of spoliation of evidence: (1) determine the degree of fault of the party who altered or destroyed the evidence; (2) determine the degree of prejudice suffered by the opposing party; and (3) determine the availability of a lesser sanction that will protect the opposing party’s rights and dete

11999–1999

Where else courts name it

NY 126 (1979–2026) CT 58 (1978–2022) PA 32 (1989–2026) TX 26 (1991–2024) MI 24 (1995–2026) NJ 23 (2001–2026) NV 20 (2004–2022) IL 16 (1992–2025) MO 15 (1987–2019) AZ 12 (2013–2024) DE 10 (2001–2025) CA 9 (2005–2023) CO 7 (1995–2025) WA 7 (2011–2023) SD 6 (1998–2022) WV 6 (1999–2017) ND 6 (1974–2014) MA 5 (1999–2018) DC 5 (1991–2019) AL 4 (1990–2012) NE 3 (1985–2021) FL 3 (2012–2021) MD 3 (1999–2016) OH 3 (2005–2025) OK 3 (2016–2022) LA 3 (1984–2007) GU 2 (2025–2025) NC 2 (2018–2025) VI 2 (2007–2013) IN 2 (1986–2026) TN 2 (2002–2022) NM 2 (2025–2025) NH 2 (1999–2009) UT 2 (2017–2023) IA 2 (2013–2020) KY 2 (2002–2006)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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