Tag Archives: Stored Communications Act

Court Finds Fourth Amendment Protects Email Privacy

On December 14, 2010, the United States Court of Appeals for the Sixth Circuit ruled in United States v. Warshak that a “subscriber enjoys a reasonable expectation of privacy in the content of emails” stored, sent or received through a commercial internet service provider (“ISP”).  According to the court, the government must have a search warrant before it can compel a commercial ISP to turn over the contents of a subscriber’s emails.

In 2008, a jury sitting in the Southern District of Ohio convicted defendants Steven Warshak, Harriet Warshak and TCI Media, Inc. of various crimes relating to defrauding customers of Berkeley Premium Nutraceuticals, Inc.  Before trial, Warshak’s motion to exclude thousands of emails that the government obtained from his ISP was denied.  The defendants appealed their convictions, arguing that the government’s warrantless seizure of Warshak’s private emails violated the Fourth Amendment’s prohibition on unreasonable searches and seizures.

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Appeals Court Finds Employee Who Auto-Forwarded Supervisor’s Emails Violated Wiretap Act

The United States Court of Appeals for the Seventh Circuit has rejected a defendant’s argument that the Wiretap Act’s prohibition on interception of communications applies only to an acquisition that is contemporaneous with the communication.  In United States v. Szymuszkiewicz, No. 07-CR-171 (7th Cir. Sept. 9, 2010), the defendant faced criminal charges under the Wiretap Act for having implemented an automatic forwarding rule in his supervisor’s Outlook email program that caused the workplace email server to automatically forward him a copy of all emails addressed to his supervisor.  The defendant argued that (i) the forwarding happened only after the email arrived at its intended destination and was thus not contemporaneous with the communication, (ii) the Wiretap Act prohibits only unauthorized contemporaneous interceptions (i.e., only interceptions of communications “in flight” as opposed to communications at rest or in storage), and (iii) only the Stored Communications Act applies to unauthorized access to non-contemporaneous communications.

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Privacy Settings on Social Networking Sites May Determine Protection Under Stored Communications Act

On May 26, 2010, the court in Crispin v. Christian Audigier, Inc. quashed portions of subpoenas seeking the disclosure of private messages sent through Facebook and MySpace.  The court left open the question of whether Crispin’s wall postings and comments should be disclosed pending a more thorough review of his online privacy settings. 

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