United States v. Carlson
United States Court of Appeals for the Third Circuit
209 Fed. Appx. 181 (2006)
- Written by Alex Ruskell, JD
Facts
Allan Carlson (defendant) was an avid Philadelphia Phillies fan who was savvy about the Internet. On multiple occasions, Carlson engaged in two types of email attacks. One was a direct attack, in which Carlson would use other people’s email addresses to send thousands of emails about the Phillies to one particular address. The other was an indirect attack, in which Carlson would send one email about the Phillies from another person’s email address to several others. When using the indirect-attack method, the alleged sender often received thousands of emails that were returned as undeliverable. Carlson was charged with violating the Computer Fraud and Abuse Act by intentionally causing damage to a protected computer. At trial, Carlson denied intentionally causing damage to other people’s computers, specifically arguing that he did not know that an indirect attack would lead to thousands of returned emails for the impersonated email user. The court convicted Carlson, finding that his actions clogged the email of others, resulting in delays and sometimes leading to the purging of all emails and causing valuable business-related information to be lost. Carlson appealed to the United States Court of Appeals for the Third Circuit, arguing that there was insufficient evidence that he intended to cause any damage to any computers.
Rule of Law
Issue
Holding and Reasoning (Irenas, J.)
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