## Facts

- Robert J. Sacramona, a service-station manager, was injured on May 4, 1988 when a tire allegedly exploded during mounting and inflation.
- Sacramona selected a used 16-inch tire as a temporary replacement; the tire warned it was for use only with a 16-inch wheel.
- Sacramona later admitted he did not check the wheel’s diameter and assumed it was 16 inches because the removed tire was 16 inches; he later contended the wheel was actually 16½ inches.
- He struggled to mount the tire using a tire-mounting machine, lubricant, a hammer, and bouncing the tire; the tire then allegedly exploded during another inflation attempt.
- After the accident, the tire and wheel were put back on the vehicle without inflation and later removed and left outdoors and unprotected.
- Months later, Sacramona’s attorney obtained the tire and wheel; they were later transferred among plaintiff-retained experts over several years.
- Sacramona sued the tire manufacturer (Bridgestone/Firestone) and wheel manufacturer (The Budd Company) under negligence/product-defect and breach-of-warranty theories.
- The district court granted summary judgment for defendants based on serious prejudice from the compromised condition/availability of the wheel and related evidentiary problems, and also ruled the warranty claim barred due to prejudicial delay.
- Sacramona appealed.

## Issues

1. Whether the district court abused its discretion by imposing dispositive sanctions (via summary judgment) based on spoliation or functional loss/alteration of the central physical evidence (the tire and wheel) and resulting prejudice to defendants.
2. Whether dismissal of the breach-of-warranty claim based on prejudicial delay and evidentiary impairment was proper.

## Decision

- The First Circuit affirmed summary judgment for Bridgestone/Firestone and Budd.
- The court held the district court acted within its discretion in concluding defendants were seriously prejudiced by the condition and late availability of the wheel and tire and that severe sanctions were warranted.
- The court upheld dismissal of the warranty claim on the ground that delay, coupled with compromised evidence, made fair litigation of the claim impracticable.

## Legal Principles

- Federal courts have inherent authority and broad discretion to impose sanctions for spoliation or loss/alteration of material evidence when the opposing party is substantially prejudiced.
- In product-liability cases, the product itself can be central evidence; deterioration, alteration, or delayed production that prevents meaningful inspection can justify severe remedies, including dismissal or summary judgment.
- The severity of a spoliation sanction may be calibrated to the degree of prejudice and whether lesser measures can restore fairness in the adjudication.
- A claim may be barred or dismissed where prejudicial delay and evidentiary impairment together deprive the opposing party of a fair opportunity to test and rebut the claim.

## Conclusion

The First Circuit affirmed dispositive relief for the defendants because the compromised and belatedly produced tire-and-wheel evidence substantially impaired the defense, and the district court reasonably concluded that the resulting prejudice, including on the warranty theory, could not be cured by lesser measures.


Sacramona v. Bridgestone/Firestone, Inc., 106 F.3d 444 (1st Cir. 1997)