Markstrom v Guard Publishing Co., No. A163317, decided by the Oregon Court of Appeals on October 10, 2018, is about the prelitigation destruction of evidence. The plaintiff, as an employee of the defendant, had been reprimanded and placed on a performance improvement plan, and she had submitted a notice of grievance through her union. Then, … Continue Reading
In the case of Akers v. Mortensen, 2016 Opinion No. 50 (April 27, 2016), the Idaho Supreme Court imposed I.A.R. 11.2 sanctions sua sponte against an attorney who was no longer representing a party to the appeal. I.A.R. 11.2 provides that every document filed with the Court must be signed. This signature constitutes a certificate … Continue Reading
