DAYNIGHT, LLC v. Mobilight, Inc., 248 P.3d 1010

Daynight, KK Machinery, and LaMarr appealed sanctions order and default judgment against KK Machinery for destruction of evidence.
District court sanctioned KK Machinery under rule 37(g) for destroying a laptop and related evidence after suit was filed.
Court noted KK Machinery’s destruction showed bad faith, including statements and conduct after filing suit.
Mobilight was awarded attorney fees and costs for certain claims, and the district court did not require apportionment for all claims due to common facts.
On appeal, KK Machinery challenged the default judgment as too harsh and challenged fee/ cost award for lack of segregation, but court affirmed.
Opinion cites appellate standards for discovery sanctions and the balance of need for sanctions against harshness.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether default judgment was a proper sanction.	KK Machinery destroyed evidence in bad faith, justifying default.	Sanction of default was too harsh for alleged discovery-like violations.	Default judgment affirmed; no abuse of discretion.
Whether attorney fees were properly awarded without apportionment.	Fees overlap claims with common facts; no segregation required.	Fees should be apportioned to compensable claims only.	Fees upheld; overlapping claims allowed without segregation.

Tuck v. Godfrey, 981 P.2d 407 (Utah Ct. App. 1999) (broad discretion in sanctions for discovery violations)
Kilpatrick v. Bullough Abatement, Inc., 199 P.3d 957 (Utah 2008) (abuse-of-discretion review of discovery sanctions)
Chen v. Stewart, 123 P.3d 416 (Utah 2005) (default judgment as sanction for obstruction of justice)
Darrington v. Wade, 812 P.2d 452 (Utah Ct. App. 1991) (caution in imposing sanctions, especially default judgments)
Valcarce v. Fitzgerald, 961 P.2d 305 (Utah 1998) (attorney fees on appeal when prevailing below)
QZO, Inc. v. Moyer, 594 S.E.2d 541 (S.C. 2004) (apportionment of attorney fees when multiple claims)