In Dardeen v. Kuehling, 213 Ill. 2d 329, 821 N.E.2d 227, 290 Ill. Dec. 176 (2004), while delivering newspapers, the plaintiff was injured when he stepped into a hole in the defendant's sidewalk. Dardeen, 213 Ill. 2d at 332. After the defendant received the go-ahead from her insurer to fix the hole, the plaintiff sued the insurer for negligent spoliation of evidence. Dardeen, 213 Ill. 2d at 332. The supreme court found that the insurer could not be held liable for negligent spoliation. Dardeen, 213 Ill. 2d at 335.