Appeal from the United States District Court for the Eastern District of Michigan at Detroit.
No. 2:20-cv-10747—Linda V. Parker, District Judge.
Argued: May 2, 2024
Decided and Filed: July 8, 2024
Before: SUTTON, Chief Judge; WHITE and THAPAR, Circuit Judges.
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OPINION
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SUTTON, Chief Judge. When Stanley Dickson sold the assets of one of his businesses,
he asked his IT administrator to create email accounts for the buyers to use and permitted the
employees of the two companies to use the accounts. Several months after the deal closed, the
relationship between the parties soured and the parties tried to unwind the deal. In the interim,
the IT administrator preserved some of the emails from those accounts for the ensuing litigation.
At stake is whether the IT administrator’s search of the buyers’ email accounts violated the
Computer Fraud and Abuse Act or Stored Communications Act. It did not. When the IT
administrator entered his own credentials to search the email accounts that he managed, he did
not intentionally act without authorization and he did not intentionally exceed his authorization. |