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Fourth Circuit· 3/6/2019

Patrick Hately v. Dr. David Watts

Citations

  • 917 F.3d 770

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

  • noting that the SCA was enacted to protect against illicit access to stored communications in “remote computing operations and large data banks that stored emails”
  • holding that “previously opened and delivered emails fall within” Section 2510(17)(B)
  • explaining that statutory interpretation “begin[s] with the plain language” of statute, and “[i]f the plain language is unambiguous, we need look no further” (internal quotation marks omitted)
  • noting that when emails are stored using a web-based server, like the Google cloud system, then the user’s “computer or mobile device merely serves as a conduit to access the [host’s] server.”
  • noting that statutory interpretation must “begin with the plain language”
  • noting majority of courts have found that subsections (A) and (B) identify “two discrete types” of protected communications

Source: CourtListener parenthetical corpus (CC0).

Judges: Gregory, Motz, Wynn

Read full opinion on CourtListener

Cited by

13 cases in this archive cite this case.

Cites

51 cases in this archive are cited by this case; the 20 most cited are listed.

Sourced from CourtListener / Free Law Project (CC0).

This is legal information, not legal advice. Laws vary by jurisdiction and change frequently. Always verify current law with official sources and consult a licensed attorney in your jurisdiction for advice on your specific situation.