Rachel Tyler, administrator of Jaccolah Johnson’s estate, obtained a jury verdict in a negligence action against the Metropolitan Atlanta Rapid Transit Authority after Johnson fell while descending a paratransit-bus stairway. MARTA appealed the trial court’s instruction on spoliation of evidence. The Court of Appeals of Georgia held that the instruction was given in error and reversed the judgment, vacated the attorney-fee award, and remanded for a new trial. The opinion explains that the plaintiff requested the spoliation instruction without first filing a motion seeking a sanction for the alleged failure to preserve surveillance video, while the record required more careful treatment of that significant issue. The court’s ruling required the trial court to reconsider the evidentiary and sanction questions in a new trial.