California Case Summaries

Smahi v. STMicroelectronics, Inc. — Mixed employment ruling permits disability and tort claims and imposes spoliation inference

Unreported / Non-Citable

Case
Smahi v. STMicroelectronics, Inc.
Court
U.S. District Court — Northern District of California
Judge
P. Casey Pitts (Joseph R. Biden Jr., 2023)
Date Decided
2026-09-08
Docket No.
5:23-cv-06645
Status
Unreported / Non-Citable
Topics
disability discrimination, workplace assault, summary judgment, evidence spoliation, adverse inference

Background

Rachid Smahi asserted numerous employment and tort claims against STMicroelectronics and individuals, including disability-related theories and claims arising from an alleged workplace confrontation. The defendants sought summary judgment, and ST separately sought sanctions over destroyed evidence.

The ruling addresses the dispute at its current procedural stage and does not resolve issues the court expressly left for later proceedings.

The Court’s Holding

The court granted summary judgment on several counts but allowed others—including identified disability and assault-related theories—to proceed. It also granted spoliation sanctions in part, concluding that jurors may infer destroyed evidence would have harmed Smahi’s position rather than imposing case-ending sanctions.

The result follows from the governing pleading, jurisdictional, or merits standard applied to the record before the court.

Key Takeaways

  • Employment cases often rise or fall on notice: merely saying an employee is sick may not tell an employer that statutory accommodation duties are triggered.
  • Separately, parties must preserve relevant evidence once litigation is reasonably foreseeable; an adverse-inference instruction can materially reshape trial.
  • Practitioners should preserve the documents and technical evidence needed to prove the rule applies to the client’s specific facts.

Why It Matters

Employment cases often rise or fall on notice: merely saying an employee is sick may not tell an employer that statutory accommodation duties are triggered. Separately, parties must preserve relevant evidence once litigation is reasonably foreseeable; an adverse-inference instruction can materially reshape trial.

The decision is unreported and may be persuasive rather than binding, but it offers a current view of how a Northern District of California judge is applying these rules.

Read the full opinion (PDF) · Court docket

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