Even if he did routinely have his phone destroyed, he could've backed up his SMS messages beforehand as a result of the pending investigation. Instead he clearly chose to destroy potentially incriminating evidence.
Don't overlook the fact that the NFL did NOT request his cell phone. They simply requested the relevant messages that would prove his lack of involvement. He was told he could provide these messages through his lawyer. He and his lawyer were informed beforehand that they would believe he had provided all relevant messages. The NFL does NOT have the authority to request access to his messages through his carrier.
Basically, he could've provided bogus messages at his own discretion and they would've taken his word for it. Had he gone this route, guilty or not, his cooperation wouldn't have been in question and the suspension wouldn't have been 4 games to begin with.
He looks guilty through his own lack of cooperation and it would be ridiculous for a court to grant an injunction, much less overturn Goodell's ruling.