Spoliation of Evidence

When a party is once found to be fabricating, or suppressing, documents, the natural, indeed the inevitable, conclusion is that he has something to conceal, and is conscious of guilt.

--Judge Learned Hand (upon finding that a ship's log had been "dressed up to excuse the ship's faults"), Warner Barnes & Co. v. Kokosai Kisen Kabushiki Kaisha, 102 F.2d 450, 453 (2d Cir. 1939).