CONLAN ABU; RYAN MOORE v. STANLEY B. DICKSON; DICKSON & ASSOCIATES, PC - Articles

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CONLAN ABU; RYAN MOORE v. STANLEY B. DICKSON; DICKSON & ASSOCIATES, PC

Posted by: Karen Belcher on Jul 8, 2024

Court: 6th Circuit Court (Published Opinions)

Attorneys 1: ARGUED: R. Christopher Cataldo, TAFT STETTINIUS & HOLLISTER, LLP, Southfield, Michigan, for Appellants.

Attorneys 2: ARGUED: Phillip J. DeRosier, DICKINSON WRIGHT PLLC, Detroit, Michigan, for Appellees.

Attorneys 3: ON BRIEF: R. Christopher Cataldo, James W. Rose, TAFT STETTINIUS & HOLLISTER, LLP, Southfield, Michigan, for Appellants.

Attorneys 4: ON BRIEF: Daniel D. Quick, DICKINSON WRIGHT PLLC, Troy, Michigan, for Appellees.

Judge(s): SUTTON, Chief Judge; WHITE and THAPAR, Circuit Judges

Court Appealed: Appeal from the United States District Court for the Eastern District of Michigan at Detroit

SUTTON, Chief Judge. When Stanley Dickson sold the assets of one of his businesses, he asked his IT administrator to create email accounts for the buyers to use and permitted the employees of the two companies to use the accounts. Several months after the deal closed, the relationship between the parties soured and the parties tried to unwind the deal. In the interim, the IT administrator preserved some of the emails from those accounts for the ensuing litigation. At stake is whether the IT administrator’s search of the buyers’ email accounts violated the Computer Fraud and Abuse Act or Stored Communications Act. It did not. When the IT administrator entered his own credentials to search the email accounts that he managed, he did not intentionally act without authorization and he did not intentionally exceed his authorization.

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