The latest California Verdict Search (reports available in paper version only) reports a defense verdict in the United States District Court for the Southern District of California (that's
San Diego) in a case called Wawanesa General Insurance Company v. Applica Consumer Products, Inc. The case is not one of great consequence -- a fire subrogation case involving a Black & Decker toaster, with about $266,000 at stake.
But the interesting thing is the report that
This is the kind of sanction we are much, much more likely to see in Federal Court than in California state court. You can see the defendant's two briefs on the spoliation issue here and here. The proposed jury instruction (which the court evidently gave) is here. You may not be surprised to learn that the jury deliberated 22 minutes before returning its defense verdict. Maybe it was a long walk to the jury room.