Charles v. City of New York (E.D. N.Y., 2017)
Key Insight: Court ruled that it could not be inferred from mere negligence that the recording would be favorable to defendants. Other sources of information/discovery were available as well. An application of Rule 37(e) would make no difference (the rule was not cited).
Nature of Case: Civil rights
Electronic Data Involved: Deleted cell phone video
Keywords: spoliation, sanctions, adverse inference