What is the test for whether a party intentionally concealed or destroyed evidence?

CACI No. 204 provides: "You may consider whether one party intentionally concealed or destroyed evidence. If you decide that a party did so, you may decide that the evidence would have been unfavorable to that party." CACI No. 204 should be given only if there was evidence of suppression. (Sprague v. Equifax, Inc. (1985) 166 Cal.App.3d 1012, 1051.) Plaintiffs cite to the purported evidence of tampering in section III.B. above. Plaintiffs also cite to the photograph of defendant's vehicle at his father's house taken the day after the accident, which showed a

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