Nah. For any number of reasons but there was no pending Court proceeding nor was there one pending or likely pending. It needs to almost rise to the level of obstruction and, not, this doesn’t.
There does not have to be a pending court proceeding. It's already pointed out and proven science that The state department requested all public records from Hillary so they can respond to congressional investigators. After which, she sent 30k and deleted some 30k
Her excuse is, they weren't public records that she deleted -- and therein is the spoliation.