State v. Azar

Summary

The court held that the computer-crime statute does not encompass merely using an online platform to sell stolen property when the theft neither interferes with protected interests in a computer or its contents nor depends on computer technology to access the property obtained. Although "theft" in the statute generally includes theft by receiving, the statutory text, context, and legislative history require a more limited connection between the computer use and the theft. The court therefore reversed the denial of defendant's motion for judgment of acquittal on the computer-crime charges and remanded for further proceedings.