Sherman v. Rinchem Co., Inc., No. 11-2932 (8th Cir. 2012)
Annotate this CaseRinchem Company, Inc. fired Jeffrey Sherman after Sherman alleged lied in the course of Rinchem's investigation of complaints about his behavior. Sherman disputed Richem's allegation and contended that Rinchem's accusation defamed him and compelled him to reveal to prospective employers that he had been fired for lying. The district court granted summary judgment to Rinchem on Sherman's defamation claim. Sherman appealed, arguing that the district court (1) should have granted his motion for summary judgment as a sanction for spoliation of evidence, or, in the alternative, an adverse-inference instruction; and (2) erred in granting summary judgment on his defamation claim. The Eighth Circuit Court of Appeals affirmed, holding (1) federal law applies to the imposition of sanctions for the spoliation of evidence, and the district court did not abuse its discretion by denying a sanction for the spoliation of evidence, as Sherman conceded that Richem did not act in bad faith; and (2) the district court did not err in granting summary judgment on Sherman's spoliation of evidence claim, as Rinchem was entitled to qualified privilege that defeated the claim.
Court Description: Civil case - Defamation. Federal law applied to imposition of sanctions for spoilation of evidence and where there was no evidence that defendant's failure to maintain certain interview notes was intentional, plaintiff was not entitled to summary judgment or an adverse-inference instruction as sanctions; assuming for the purposes of analysis that the alleged defamatory statement was communicated to someone other than plaintiff and tended to harm plaintiff's reputation, the employer established the existence of the qualified privilege and plaintiff failed to show that the employer abused the privilege by acting with actual malice.
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