United States v. Mitra

The City of Madison, Wisconsin, used a computer-based radio system for police, fire, ambulance, and other emergency communications. Computer hardware and software assigned each communication to an open channel and linked individual radio units together to enable communication between officers in the field. Over the course of a couple of years, the city experienced issues with the radio system’s control channel, resulting in remote units being unable to communicate with each other. An investigation uncovered that a hacker was causing the system issues, and police arrested Rajib Mitra (defendant), a graduate student at the University of Wisconsin. Mitra held a degree in computer science and had two prior convictions for hacking computers. Mitra was convicted of two counts of internal interference with computer-related systems in interstate commerce in violation of the Computer Fraud and Abuse Act (CFAA) in connection with his hacking of the city’s communication system. He appealed, arguing that his conduct did not violate the CFAA, which he claimed criminalized interference with computer systems but not radio systems. The United States argued that the CFAA’s definition of a computer as an electronic, magnetic, optical, electrochemical, or other high-speed data-processing device included radio systems like the one the Madison used. In addition, the United States pointed out that the CFAA expressly excluded only a handful of items like typewriters and portable calculators, but not radios.