In Ronnie Van Zant v. Pyle, 2017 WL 3721777 (S.D.N.Y. Aug. 28, 2017), a court in the Southern District of New York recently made some notable findings relating to spoliation and control of text messages.

Members of the Southern rock band Lynyrd Skynyrd were involved in a charter plane crash in 1977. Lead singer Ronnie Van Zant and guitarist/vocalist Steven Gaines died in the crash, along with Gaines’s sister, a crew member, and the two pilots. Other band members, including drummer Artimus Pyle, were injured, but survived.