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  • Sources: 3
  • Relationships: 5
  • Research debt items: 1
  • Last verified: 2026-06-19

Van Buren v. United States

Summary

Van Buren v. United States, 593 U.S. 374 (2021), interpreted the CFAA phrase "exceeds authorized access" narrowly in a gates-up-or-down case about law enforcement database access.

Verified Facts

  • The case citation is 593 U.S. 374 (2021).
  • The case concerned 18 U.S.C. § 1030(a)(2) and the definition of "exceeds authorized access" in § 1030(e)(6).
  • The official syllabus states that an individual "exceeds authorized access" when he accesses a computer with authorization but then obtains information located in particular areas of the computer that are off-limits to him.
  • The Court held that the provision does not cover obtaining information from areas the accesser was otherwise authorized to reach but used for an improper purpose.
  • The opinion describes the CFAA's access clauses as a gates-up-or-down inquiry focused on whether a person can or cannot access particular computer areas or information.
  • The Court warned that the Government's broader reading would attach criminal penalties to a wide range of commonplace computer activity based on policy or contract violations.

Historical Context

The case arose from a police sergeant's paid license-plate lookup in a law enforcement database in violation of department policy.

The Court rejected an interpretation of "exceeds authorized access" that would criminalize authorized access followed by misuse for an improper purpose, such as a policy-violating personal lookup. The opinion emphasizes statutory structure distinguishing unauthorized access from exceeding authorized access, and it discusses the practical consequences of treating use restrictions as access restrictions under the CFAA.

Relationships

Sources

Research Debt

  • Summarize later CFAA treatment and civil liability cases with primary sources.