Mauricio A. Leon, M.D. v. Idx Systems Corporation, a Vermont Corporation, Mauricio A. Leon, M.D. v. Idx Systems Corporation, a Vermont Corporation

Dr. Mauricio Leon (“Leon”) worked as the director of medical informatics at IDX Systems Corporation (“IDX”). After he was placed on unpaid leave, Leon sued IDX, alleging violations of the anti-retaliation provision of the False Claims Act, Title VII, the Americans with Disabilities Act (“ADA”), and Washington state law. He also filed a complaint with the United States Department of Labor (“DOL”), claiming that IDX violated the whistle-blower-protection provision of the Sar-banes-Oxley Act (“SOX”). The district court dismissed all of Leon’s claims with prejudice after determining that Leon despoiled evidence by deleting 2,200 files from his IDX-issued laptop computer during the pendency of the litigation. The court also imposed a $65,000 monetary spoliation sanction. Leon appeals the sanctions and IDX cross-appeals the district court’s decision not to enjoin, on res judicata grounds, the DOL’s proceedings against IDX. We affirm the district court’s spoliation sanctions, reverse its res judica-ta determination, and remand the case to the district court to reassess whether it should enjoin the DOL proceedings.

The district court’s jurisdiction arose under 28 U.S.C. §§ 1331 and 1367.…