Can a plaintiff sue other parties to litigation for interference with the Plaintiff's ability to prevail in a common law tort action?

Plaintiff contends that her constitutional right of free access to the courts bars private persons from destroying objects of potential relevance to a lawsuit, and requires that we recognize a spoliation cause of action against nonparties as well as parties to the litigation. Plaintiff cites cases discussing a litigant's right of access to the courts, but these opinions do not suggest that recognition of this right requires that private persons be barred from disposing of objects that may prove to be relevant in a lawsuit, nor that this right includes a constitutional right to hold the offending private party accountable under common law tort principles for its destruction of evidence. We are unaware of any authority investing parties to litigation with a constitutional right to sue other private persons in a common law tort action for interference with the party's ability to prevail in a lawsuit. (See, e.g., Werner v. Southern Cal. etc. Newspapers (1950) 35 Cal.2d 121, 125-126, 216 P.2d 825.) ⁵