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SPOLIATION OF EVIDENCE In Cedars-Sinai Medical Center v. Superior Court (1998) 18 Cal.4th 1, the California Supreme Court did away with the tort of intentional spoliation of evidence: ...we hold that there is no tort remedy for the intentional spoliation of evidence by a party to the cause of action to which the spoliated evidence is relevant, in cases which, as here, the spoliation victim knows or should have known of the alleged spoliation before the trial or other decision on the merits of the underlying action.... [18 Cal.4th 1, 17-18; fn. omitted.]