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Evidence Preservation Guide

Spoliation Letters: Preserving Truck Accident Evidence

Critical evidence disappears within weeks of a truck accident. Preservation letters create a legal duty to retain data—and severe sanctions if it's destroyed.

Key Takeaways

  • Legal Duty: A preservation letter creates a legal obligation to retain evidence. Destruction after notice is spoliation.
  • Send Immediately: ELD backups overwrite in 30-60 days. ECM data overwrites with new events. Time is critical.
  • Send to Everyone: Carrier, driver, broker, insurer, ELD provider—anyone who might have evidence.
  • Severe Sanctions: Courts can instruct juries to assume destroyed evidence was harmful to the destroying party.

Why Evidence Preservation Matters

Trucking companies know that electronic data can prove liability. After a serious accident, their first call is to their lawyers and insurance adjusters—who know exactly how to make evidence "disappear" through "routine business practices."

Evidence Vanishes

Without a preservation letter, carriers can claim data was "routinely overwritten" before litigation began.

Legal Duty Created

A preservation letter creates a formal legal obligation. Destruction after receipt is sanctionable spoliation.

Protects Your Case

Preserved evidence often proves what the trucker and carrier deny. The truth is in the data.

The Defense Playbook

Defense attorneys for trucking companies know that electronic data is often the most damaging evidence. Without a preservation letter creating a litigation hold, they may allow "routine" data destruction to continue—eliminating the very evidence that would prove your case.

What Evidence to Preserve

A comprehensive preservation letter demands retention of all potentially relevant evidence—not just the obvious items.

Electronic Data

URGENT
  • ELD records (30+ days before accident)
  • ECM/black box data
  • GPS and telematics data
  • Dispatch communications
  • Email and text messages

Physical Evidence

URGENT
  • The truck and trailer
  • Tires, brakes, and components
  • Driver's personal effects
  • Cargo and load securement
  • Debris from crash scene

Documents

  • Driver qualification files
  • Training and certification records
  • Drug/alcohol testing results
  • Maintenance and inspection records
  • Bills of lading and trip records

Surveillance

URGENT
  • Dash camera footage
  • In-cab camera footage
  • Nearby business cameras
  • Traffic cameras
  • Body cameras (if police involved)

Who Should Receive a Preservation Letter

Don't limit yourself to the trucking company. Multiple parties may possess critical evidence—and each needs a separate preservation demand.

RecipientWhy They Get a Letter
Motor CarrierPrimary defendant; controls truck, driver files, and most records
Driver (Personal)May have personal cell phone, dash cam, or other evidence
Freight BrokerMay be liable; has load assignment and communication records
Insurance CarrierMay have investigation files, recorded statements, photos
ELD ProviderMaintains independent copy of ELD data outside carrier control
Leasing CompanyIf truck is leased, may have maintenance and inspection records

Strategic Note: By sending letters to ELD providers and telematics companies directly, we obtain data independent of what the carrier chooses to produce. These third parties often have unaltered data the carrier can't "lose."

Critical Timing Windows

Different types of evidence have different retention windows. Waiting even a few weeks can mean the loss of crucial data.

Send preservation letters

24-48 hrs

ELD backup data may overwrite

30-60 days

Surveillance footage typically overwrites

30-90 days

Federal ELD retention minimum

6 months

ECM data overwrites with new events

Varies

Our Practice

We send comprehensive preservation letters within 24-48 hours of engagement—often the same day we speak with the client. Evidence preservation is always our first action in any serious truck accident case.

Remedies for Spoliation

When a trucking company destroys evidence after receiving a preservation letter—or when litigation is reasonably foreseeable—courts can impose serious sanctions.

Adverse Inference Instruction

The court tells the jury it may assume the destroyed evidence was harmful to the party that destroyed it. This is devastating in front of a jury.

Monetary Sanctions

Courts can order the spoliating party to pay attorney's fees, expert costs, and other expenses incurred due to the evidence destruction.

Exclusion of Evidence

The court may exclude related evidence or prohibit the spoliating party from offering testimony on subjects covered by destroyed evidence.

Default Judgment

In extreme cases of intentional destruction, courts may strike the defendant's answer and enter judgment for the plaintiff on liability.

Frequently Asked Questions

A spoliation letter (also called a preservation letter or litigation hold) is a formal written demand that a party preserve all evidence relevant to anticipated litigation. Once received, the recipient has a legal duty to preserve that evidence and cannot claim 'routine destruction' as an excuse.
Immediately—ideally within 24-48 hours of a serious truck accident. ELD backup data may overwrite within 30-60 days. ECM data can be overwritten by new driving events. Surveillance footage, dispatch communications, and cell phone records also have limited retention windows.
Courts can impose severe sanctions for spoliation: adverse inference instructions (telling the jury to assume the destroyed evidence was harmful to the company), monetary sanctions, exclusion of related evidence, or even default judgment in extreme cases. Spoliation can also support independent claims.
Multiple parties: the trucking company (carrier), the driver personally, any brokers involved, the insurance carrier, the ELD provider, and any other party that may possess relevant evidence. Sending to all potential defendants and data custodians ensures comprehensive preservation.
Yes, but it's best done by an attorney. A lawyer-drafted letter carries more weight, uses proper legal language, and establishes a clear record. An attorney letter also signals that litigation is genuinely anticipated, strengthening the duty to preserve.

Need to Preserve Critical Trucking Evidence?

We send comprehensive preservation letters within 24-48 hours of engagement. Don't let critical evidence disappear. Contact us immediately.

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