Stubli v. Big D International Trucks, Inc.

Rose, J.,

dissenting,

with whom Springer, J., agrees:

The dismissal of Stubli’s complaint constitutes a sanction *315which is unnecessarily harsh. An attorney and expert witness employed by Stubli’s insurance company and also representing Stubli made a decision before litigation commenced to destroy portions of the trailer. They believed those portions were not essential to determine the cause of the accident. This decision was not willfully made to impede any potential defendants; the defense experts have not been prevented from forming an opinion as to the cause of the accident, and a less severe sanction would better serve the interests of justice. For these reasons, I dissent.

The dispute between the parties concerns how the accident happened. The highway patrol believed Stubli fell asleep at the wheel and his truck drifted into the median. Stubli’s experts conclude that a weld repair was defective or a fatigue fracture developed near the weld. The defense experts opine that the trailer was overloaded and this damaged the springhangers and associated parts, thus causing the crash. Stubli’s experts contend that all trailer parts necessary for accident reconstruction were preserved. The defense experts believe sufficient evidence exists to form an opinion as to the cause of the accident, but that the destroyed section might be helpful to bolster their opinion and refute the speculation of one of Stubli’s experts. The respondents did not assert that the destroyed trailer was necessary to their defense until the filing of the motion to dismiss in question, almost two years after their experts inspected the preserved tractor parts.

Against this factual background, we must review the factors set forth in the Young case to determine whether the extreme sanction of dismissing the complaint was warranted. See Young v. Johnny Ribeiro Building, 106 Nev. 88, 787 P.2d 111 (1990). The refrigeration unit and axles of the trailer were destroyed because Stubli’s attorney and expert had determined that a defective weld repair caused the accident and that preserving more than the sliding axle assembly was unnecessary because “the evidence collected plus what we preserved is all the data that [a reasonable engineer] needs to determine what happened.” There were hundreds of photographs taken of the discarded portions of the trailer that were made available to the respondents. There is no indication in the record that the destruction of the trailer was done in bad faith to frustrate any of the potential defendants and it was not in violation of any court order because suit had not yet been filed. This is not a willful destruction of evidence.

Two other Young factors that weigh in Stubli’s favor are the considerations of whether the non-offending party would be prejudiced by a lesser sanction and whether a less severe sanction would be feasible. The defense experts have not been prevented *316from forming and advocating an opinion as to the cause of the accident, but may be prevented only from buttressing their conclusion that the accident happened because of overloading. Even the district court recognized this when it stated in its order that the jettisoned portion of the trailer “may have provided defendants with evidence supporting their theory of the case.” Therefore, it is doubtful whether the evidence in question would have been of any assistance to either party had it not been destroyed.

The district court could have permitted the case to go to trial and then instructed the jury that if it found that any destroyed evidence would be significant in reaching a conclusion as to the cause of the accident, it should infer that the evidence destroyed would have disclosed facts adverse to the party who destroyed it. Additionally, the court could have prevented Stubli’s expert from testifying about his observations of the refrigeration unit before it was discarded. These remedial sanctions would have enabled the defense to present their theory of the case and suffer only minimal prejudice.

Another factor to be considered is whether sanctions unfairly operate to penalize a party for the misconduct of his or her attorney. The complaint’s dismissal does just that; it penalizes Stubli for the action taken by an expert and attorney representing both Stubli and his insurance company seeking subrogation. It was Stubli’s insurance company that continually complained that the costs of storing the entire trailer were mounting. The impetus to destroy the remainder of the trailer came not from Stubli, but from his insurer, who presumably was paying and directing the attorney and expert.

Finally, public policy favors adjudication on the merits whenever possible. Hotel Last Frontier v. Frontier Prop., 79 Nev. 150, 155, 380 P.2d 293, 295 (1963). The destroyed parts of the trailer were not essential to the trial of this case and remedial sanctions were feasible. Imposition of the extreme sanction of dismissal with prejudice was an abuse of discretion by the district court. For these reasons, I respectfully dissent from the majority opinion.