Brown Jordan International, Inc. v. Carmicle

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The parties filed cross-complaints after Christopher Carmicle was terminated from Brown Jordan. After the district court entered judgment for Brown Jordan, Carmicle appealed. Carmicle raised issues regarding the Computer Fraud and Abuse Act (CFAA), 18 U.S.C. 1030, the Stored Communications Act (SCA), 18 U.S.C. 2701, wrongful discharge, and breach of an employment agreement. The court concluded that Carmicle’s CFAA arguments fail because Brown Jordan suffered “loss” as defined in the CFAA; Carmicle waived his unopened-versus-opened-email argument under the SCA because he did not fairly present it to the district court, and Brown Jordan showed Carmicle exceeded his authorization in accessing the emails of other Brown Jordan employees; and the district court did not err in granting summary judgment on Carmicle’s wrongful discharge claim or in concluding that Carmicle was terminated for cause as defined by the Employment Agreement. Accordingly, the court affirmed the judgment. View "Brown Jordan International, Inc. v. Carmicle" on Justia Law