Markstrom v. Guard Publ'g Co.

*339Plaintiff appeals a general judgment of dismissal, which the trial court entered as a sanction for spoliation of evidence-specifically, destruction of plaintiff's email and text messages. Even though plaintiff deleted most or all of the material in question before filing her cause of action, the trial court ultimately concluded-relying on ORCP 46 D, a rule governing sanctions for discovery violations, and related case law, namely Pamplin v. Victoria , 319 Or. 429, 877 P.2d 1196 (1994) -that, because plaintiff knew when she destroyed the emails and text messages that "litigation was reasonably…