Supreme Court of Georgia

The Anthem Companies, Inc. v. Wills

February 4, 2019823 S.E.2d 781

Summary

The Supreme Court of Georgia reversed the trial court’s spoliation sanctions against Anthem Companies and Richard Andrews, holding that the loss of printed copies of electronically stored photographs did not constitute spoliation warranting severe sanctions. The Court found the trial court abused its discretion because the electronic images remained preserved and no bad‑faith intent or irrecoverable prejudice was shown.