Snow v. DirecTV, Inc.

Khilansha MukhijaCase Summary

Does the Storage Communications Act offer protection to a publicly available website?

Snow v. DirecTV, Inc.
450 F.3d 1314
In the United States Court of Appeals for the Eleventh Circuit
Case Number 05-13687
Before Circuit Judge Carnes, Circuit Judge Wilson, and Circuit Judge Pryor
Decided on June 01, 2006

Relevancy of the case: Does the Storage Communications Act offer protection to a publicly available website?

Statutes and Provisions Involved

  • The Stored Communications Act, 18 U.S.C. § 2701 et seq. (“SCA”)
  • The Federal Rules of Civil Procedure (Rule 12(b)(6))

Relevant Facts of the Case

  • The appellant, Snow, created a private support group website with an electronic bulletin board.
  • He restricted the members associated with the respondent, DirecTV, and law firms Yarmuth and Stump from registering on his website.
  • Employees of DirecTV and the abovementioned law firms accessed the website’s electronic bulletin board without authorisation, which allegedly violated the provisions of the SCA.
  • The district court dismissed Snow’s complaint, ruling that the electronic bulletin board was not an “electronic storage”. Hence, it will be out of the scope of protection under the SCA.

Prominent Arguments by the Counsels

  • The appellant’s counsel argued that:
    • Employees of DirecTV, Stump, and Yarmuth accessed the electronic bulletin board on Snow’s website without authorisation, breaching their conditions under the SCA.
    • The electronic bulletin board should be considered “electronic storage” under the SCA, thus making unauthorised access illegal.
  • The respondent’s counsel submitted that:
    • The messages on Snow’s electronic bulletin board do not meet the SCA’s “electronic storage” definition.
    • Snow’s website was configured to allow public access, which does not meet the SCA’s protection requirements.

Opinion of the Bench

  • Snow’s website wasn’t configured to restrict public access, i.e., it was easily available for public use. This availability will fail the requirements to make the defendants’ actions illegal under the SCA.

Final Decision

  • The court ruled against Snow and dismissed his claims by rejecting the appeal.