Caryl Rosen v. Community Healthcare System d/b/a Community Hospital

Summary

The Indiana Supreme Court affirmed the judgment for Community Hospital, holding that the trial court acted within its discretion in finding no spoliation, refusing an adverse-inference instruction, and excluding evidence concerning unpreserved video. The hospital reasonably preserved the footage that captured the fall, and the record supported the trial court's conclusion that the additional footage was not reasonably likely to be relevant or discoverable. The court also held that evidence concerning the other cameras did not establish an inconsistent statement, was not shown to be relevant to the expert's opinion, and did not correct any misleading impression.