Missouri Court of Appeals, Eastern District / Apr 1, 2025
William Sandbach, et al., Appellants, v. KMS-KFC, LLC, et al., Respondents.
Appellants William and Jennifer Sandbach sued KMS-KFC, LLC, and KFC Corporation, Inc., alleging various torts after a confrontation with employees, during which security video evidence was destroyed. After the trial court granted summary judgment on most counts in the underlying case, Appellants filed an independent lawsuit for spoliation of evidence. The appellate court affirmed the circuit court's dismissal of the spoliation action, holding that Missouri does not recognize an independent cause of action for spoliation of evidence, and also denied Respondents' request for damages for a frivolous appeal.