In the Federal system, spoliation sanctions spring from two main sources of authority. First, sanctions may be based on the court's inherent power to control the judicial process and litigation, a power that is necessary to redress conduct “which abuses the judicial process.” Chambers v. NASCO, Inc., 501 U.S. 32, 45–46, 111 S.Ct. 2123, 115 L.Ed.2d 27 (1991) (recognizing the inherent power of *264 the courts to fashion appropriate sanctions for conduct that disrupts the judicial process); see also
Shepherd v. American Broadcasting Cos., 62 F.3d 1469, 1474–75 (D.C.Cir.1995); see generally
Roadway Express, Inc. v. Piper, 447 U.S. 752, 764–65, 100 S.Ct. 2455, 65 L.Ed.2d 488 (1980). Although established under Article I of the Constitution, this court, no less than any Article III tribunal, possesses this form of inherent authority. See
United Medical Supply Co., 73 Fed.Cl. at 36; Pueblo of Laguna v. United States, 60 Fed.Cl. 133, 136 (2004).
Second, where the spoliation violates a specific court order or disrupts the court's discovery regime, sanctions also may be imposed under Fed.R.Civ.P. 37, which is essentially identical to its counterpart under this court's rules. See
RCFC 37; Zoltek Corp. v. United States, 71 Fed.Cl. 160, 167 (2006). In either instance, the policies underlying the sanctions are multifaceted: to punish the spoliator, so as to ensure that it does not benefit from its misdeeds; to deter future misconduct; to remedy, or at least minimize, the evidentiary or financial damages caused by the spoliation; and last, but not least, to preserve the integrity of the judicial process and its truth-seeking function. See
West, 167 F.3d at 779; Gorelick, supra,
at § 3.14; see also
Nat'l Hockey League v. Metro. Hockey Club, Inc., 427 U.S. 639, 642–43, 96 S.Ct. 2778, 49 L.Ed.2d 747 (1976). In keeping with these broad rationales, courts have held that, like any other litigant, the United States is subject to spoliation sanctions either under the court's inherent authority or the sanction provisions of Rule 37—and defendant has not argued otherwise. See, e.g.,
M.A. Mortenson Co. v. United States, 996 F.2d 1177, 1183–84 (Fed.Cir.1993) (citing additional cases); see also
Chilcutt v. United States, 4 F.3d 1313, 1325–26 (5th Cir.1993), cert. denied, sub nom.,
Means v. Wortham, 513 U.S. 979, 115 S.Ct. 460, 130 L.Ed.2d 367 (1994); United States v. National Medical Enters., Inc., 792 F.2d 906, 912 (9th Cir.1986).