112932P.pdf   08/06/2012  Jeffrey Sherman  v.  Rinchem Company, Inc.
   U.S. Court of Appeals Case No:  11-2932
   U.S. District Court for the District of Minnesota - Minneapolis   
   [PUBLISHED] [Smith, Author, with Riley, Chief Judge, and Melloy,
   Circuit Judge]
   Civil case - Defamation. Federal law applied to imposition of sanctions
   for spoilation of evidence and where there was no evidence that
   defendant's failure to maintain certain interview notes was intentional,
   plaintiff was not entitled to summary judgment or an adverse-inference
   instruction as sanctions; assuming for the purposes of analysis that the
   alleged defamatory statement was communicated to someone other than
   plaintiff and tended to harm plaintiff's reputation, the employer
   established the existence of the qualified privilege and plaintiff failed to
   show that the employer abused the privilege by acting with actual malice.