Holloway v. County of Orange (C.D. Cal. 2021)
Key Insight: The court granted defendants’ motion for sanctions based on spoliation of evidence based on plaintiff’s deletion of his Facebook account. “Plaintiff had an obligation to preserve his Facebook account, he deleted the account with a culpable state of mind, and the account was relevant to Defendants’ claims.” The court further ordered that an adverse inference jury instruction was appropriate.
Nature of Case: Civil Rights
Electronic Data Involved: Social Media, Facebook