dence is the destruction or loss of evidence requested by a plaintiff in a case with the result being that the plaintiff loses the opportunity to advance the case. To establish the tort of negligence, one must show that there has been a breach of duty in the form of a violation of a statute or professional competency stan- dards or of behavior that does not rise to the level of that of a reasonable person. That breach of duty must have caused the injuries to the plaintiff, and the plain- tiff must be able to quantify the damages that resulted. Possible defenses to negligence include contributory negligence, comparative negligence, and assumption of risk. Strict liability is absolute liability with few defenses. Liability for torts has been expanding in terms of the amounts awarded and the persons who can be held liable. Currently, there are numerous statutes, deci- sions, and ballot propositions on limiting tort liability