Malinowski v. Documented Vehicle/Drivers Systems, Inc.

The Appellant, Elaina Malinowski, appeals from the district court’s order granting summary judgment to Appellees, United Parcel Service, Inc. (“UPS”) and Documented Vehiele/Drivers Systems, Inc. (“DVD”). Ms. Malinowski argues that the district court erred when it ruled that the Rhode Island Supreme Court would not recognize an independent tort for spoliation of evidence and that it further erred in concluding that, even supposing it did recognize such a cause of action, she failed to meet the essential elements. We find it unnecessary to rule on the first ground and affirm on the second…