Patrick Hately v. Dr. David Watts

WYNN, Circuit Judge:

Patrick Hately brought this action alleging that David Watts unlawfully accessed messages in Hately's web-based email account in violation of the Virginia Computer Crimes Act and the federal Stored Communications Act. But the district court found that Hately failed to demonstrate the requisite statutory injury under state law, and that Hately's previously opened and delivered emails stored by a web-based email service were not in statutorily protected "electronic storage" under federal law. We disagree with both determinations and therefore reverse and remand this case to…