The gravamen of the complaint in Morrison v. Rankin, 738 N.W.2d 588 (Wis. App. 2007) was medical malpractice. As a sanction for spoliation committed by the defendants, the court directed a verdict in favor of the plaintiff on the issue of informed consent. The defense then admitted that the surgery caused permanent nerve injury and, after a trial limited to damages alone, the jury returned a verdict in excess of $2.2 million. The defendants’ insurers denied coverage on the ground that they afforded no insurance for spoliation, and it was spoliation that produced the award. The Wisconsin Court of Appeals rejected the contention, distinguishing cases in which the tort of spoliation was the underlying cause of action (and in which denials of coverage had elsewhere been upheld) from the case before it, in which procedural spoliation sanctions were imposed in an action that fell within the coverage afforded by the policy. The Morrison Court held that the carriers’ ‛obligation to insure does not arise from spoliation sanctions; it arises from the terms of its medical malpractice policy insuring [the physician] against claims for negligent medical acts undertaken in the course of rendering professional medical care.“ Denials of coverage rejected.