A Virginia state judge ordered a prominent Virginia lawyer to pay $522,000 for instructing his client to remove unflattering photos from his Facebook profile before taking his wrongful death case to trial. The lawyer, understandably, did not want to be surprised at trial by photos of his client with alcohol in hand and a lewd t-shirt on. It certainly would not make for a sympathetic and grieving husband at trial. But, the judge considered this spoliation.
Here is a copy of an article giving the details:
http://blog.x1discovery.com/2011/11/15/facebook-spoliation-costs-lawyer-522000-ends-his-legal-career/