United States v. Nicholas Middleton
231 F.3d 1207
In the United States Court of Appeals for the Ninth Circuit
Case Number 99-10518
Before Circuit Judge S.P. Graber, Circuit Judge R.C. Fisher, and Circuit Judge M.S. Berzon
Decided on November 16, 2000

Relevancy of the Case: Does damage under Section 1030 also cover damages caused to a corporation?

Statutes and Provisions Involved

• The Computer Fraud and Abuse Act, 18 U.S.C. § 1030

Relevant Facts of the Case

• The defendant is a disgruntled ex-employee who changed all the administrative passwords. He altered the computer’s registry and deleted the entire billing system, including programs that ran the billing software. Moreover, he also deleted two internal databases.
• The District Court convicted and sentenced him for intentionally causing damage to a protected computer without authorisation, in violation of Section 1030(a)(5)(A).

Prominent Arguments by the Counsels

• The defendant’s counsel contended that Section 1030(a)(5)(A) excludes damages to a corporation. The trial court has incorrectly instructed the jury on the damage element. Furthermore, the prosecution presented insufficient evidence on the requisite amount of damage.

Opinion of the Bench

• Section 1030 criminalises computer crimes that damage natural persons and corporations alike.
• The District Court did not abuse its discretion in rejecting the defendant’s precise formulation of the definition of damage. The court’s instructions adequately covered the elements of the offence.

Final Decision

• The Court of Appeal rejected the defendant’s contentions and affirmed the District Court’s judgment.

Parul Anand, an undergraduate student at the National Law University, Jodhpur, prepared this case summary during her internship with The Cyber Blog India in May/June 2022.