In Cumberland Insurance Group v. Delmarva Power d/b/a Delmarva Power & Light Company, 130 A. 3d 1183 (Md. App. 2016), the Court of Special Appeals of Maryland (the Court) addressed an issue of first impression: the appropriate spoliation sanction when the physical object that was destroyed is, itself, the subject of the litigation. The Court, finding that the plaintiff was at fault and that the destruction of the house at issue irreparably prejudiced the defendant’s ability to defend the case, held that the trial court did not abuse its discretion when it dismissed the plaintiff’s case as a spoliation sanction.