United States v. Auernheimer
United States Court of Appeals for the Third Circuit
748 F.3d 525 (2014)
- Written by Alex Ruskell, JD
Facts
Daniel Spitler discovered a flaw that allowed anyone to collect the email addresses of iPad owners from AT&T’s computer servers. Andrew Auernheimer (defendant) helped Spitler write a program that gathered the email addresses. To bring attention to their hacking skills, Spitler and Auernheimer contacted a reporter to show him their work. Auernheimer was then charged by a New Jersey grand jury under the Computer Fraud and Abuse Act. New Jersey argued that Auernheimer could be tried there because 4,500 New Jersey residents had had their emails collected. At all times relevant to this case, Spitler was in California, Auernheimer was in Arkansas, the servers were in Texas and Georgia, and there was no evidence regarding the location of the reporter, although it was undisputed that he was not in New Jersey. The New Jersey court found venue appropriate and convicted Auernheimer. Auernheimer appealed to the United States Court of Appeals for the Third Circuit, arguing venue was not appropriate in New Jersey because no criminal conduct occurred in New Jersey.
Rule of Law
Issue
Holding and Reasoning (Chagares, J.)
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