Supreme Court of the United States
Van Buren v. United States
June 3, 2021593 U.S. 374
Summary
Justice Barrett, joined by Justices Breyer, Sotomayor, Kagan, Gorsuch, and Kavanaugh, held that the Computer Fraud and Abuse Act’s prohibition on exceeding authorized access covers obtaining information from computer areas that are off limits, not obtaining otherwise accessible information for an improper purpose. Because Van Buren was authorized to retrieve license-plate information, his retrieval for personal gain did not violate that prohibition. The Court reversed the Eleventh Circuit’s judgment and remanded. Justice Thomas dissented, joined by Chief Justice Roberts and Justice Alito, arguing that authorization is circumstance dependent and that Van Buren exceeded authorized access by retrieving information for a purpose expressly forbidden by his employer.
Holding
- Whether authorized access to computer information becomes excessive under 18 U.S.C. §1030(a)(2) when exercised for an improper purpose.. An individual exceeds authorized access when he accesses a computer with authorization but obtains information in particular areas of the computer that are off limits to him. The prohibition does not cover obtaining otherwise accessible information for an improper purpose; Van Buren therefore did not violate it.
Docket 19-783
Cited authorities
- CA11
- 18 U.S.C. §1030
- 78 N.Y.U. L. Rev. 1596
- 98 Stat. 2190
- 18 U.S.C. §1030
- 18 U.S.C. §1030
- 7 U.S.C. §171
- 18 U.S.C. §648