court has wide-ranging authority to impose sanctions for the spoliation of evidence. Ha-wai'i Rules of Civil Procedure (HRCP) Rule 37(b)(2) allows the court to “make such orders ... as are just,” including the dismissal of claims, in response to discovery violations. See, e.g., Wong, 66 Haw. at 392-94, 665 P.2d at 160-62. In addition to this rule, the circuit court also “has the inherent power ... to fashion a remedy to cure prejudice suffered by one party as a result of another party’s loss or destruction of evidence.” Richardson v. Sport Shinko (Waikiki Corp.), 76 Hawai'i 494, 507-08, 880 P.2d 169, 182-83 (1994). See also HRS § 603-21.9(6) (1993). Such a remedy may include a jury instruction such as the one given by the trial court in this ease. See id. at 508, 880 P.2d at 183 (<HOLDING>). See generally Trevino v. Ortega, 969 S.W.2d
holding that in a criminal trial the trial court must correct or amend an improper instruction if the proper instruction is necessary for the jury to understand the case holding that a trial judge is obliged to give a correct jury instruction notwithstanding that request for instruction was technically erroneous if the evidence generates the subject matter of the jury instruction holding that it was prejudicial error to fail to give such a cautionary instruction even where the defendant did not object at trial to the lack of such an instruction when the accomplice testimony was uncorroborated holding that the trial court had the authority to give an instruction if it deemed such a measure appropriate holding that it was not error for the court to give a substantive new instruction to the jury after deliberations began where the instruction was given in court with the defendant and his counsel present