In the case of In re Quintus Corp., 2006 WL 3072982 (Bankr. D. Del. Oct. 27, 2006) , the Bankruptcy Court for the District of Delaware imposed a penalty of summary judgment on a party that the court found intentionally deleted documents, including electronic data, that would have been harmful to its case. The Electronic Discovery Law Blog has a more complete summary and access to the whole case. Here is the link: $1.888 Million Judgment Entered in Favor of Bankruptcy Trustee Based on Adverse Party’s Spoliation of Financial Records : Electronic Discovery Law