id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
cblr-1760	Gross, Alexander Nourse	A Safe Harbor from Spoliation Sanctions: Can an Amended Federal Rule of Civil Procedure 37(e) Protect Producing Parties?	2015	59	.pdf	application/pdf	21485	943	53	However, as this Note argues, the proposed Rule will not be successful in creating a uniform national standard governing when judges may issue severe sanctions because (1) it does not limit judges’ inherent power to sanction parties notwithstanding the Federal Rules and (2) it contains a loophole that could be  Second, because of the inherent power of judges to sanction parties and different common law standards for imposing sanctions among the circuits, Rule 37(e) was inconsistently enforced by courts in different circuits—and, in some instances, within the same circuit.	cache/cblr-1760.pdf	txt/cblr-1760.txt