Van Buren v. United States

Nathan Van Buren (defendant) was a police sergeant in Georgia. Van Buren formed a relationship with a man named Andrew Albo. Van Buren had asked Albo for a personal loan, and Albo secretly recorded the encounter. Albo brought the recording to the local sheriff’s office and complained Van Buren had tried to shake him down for cash. The Federal Bureau of Investigation (FBI) heard the recording and devised an operation to investigate Van Buren. The FBI had Albo request Van Buren to search the state law-enforcement computer database for a license plate purportedly belonging to a woman Albo met at a strip club. Albo told Van Buren he wanted to make sure the woman was not an undercover officer and that he would give Van Buren $5,000 in exchange for the information. Van Buren used his patrol-car computer to access the law-enforcement database with his valid credentials and searched the database for the license plate. Van Buren obtained the FBI-created license-plate entry and reported it to Albo. The federal government (plaintiff) subsequently charged Van Buren with a felony violation of the Computer Fraud and Abuse Act of 1986 (CFAA). The CFAA subjected criminal liability to anyone who “intentionally accesses a computer without authorization or exceeds authorized access” and uses that access to obtain information. Van Buren was tried and convicted by a jury in district court. Van Buren appealed. The court of appeals held that Van Buren had violated the CFAA by accessing the law-enforcement database for an unauthorized reason. The Supreme Court granted certiorari.