Illinois Supreme Court
Civil Court
Spoliation of Evidence
General contractor had no duty, based on voluntary undertaking or other special circumstance, to preserve concrete I-beam supporting bridge deck on which employees were standing; I-beam collapsed and employees fell into creek and were injured. Spoliation of evidence claims cannot stand in absence of duty to preserve evidence. (FREEMAN, THOMAS, GARMAN, KARMEIER, and THIS, concurring; KILBRIDE, dissenting.)