Summary of Intel Corp v. Hamidi, 71 P.3d 296 (Cal. 2003)
Facts: Intel Corp, P, sued Hamidi, D, an employee of P, for trespass to chattel because D was sending out numerous emails over an inter-office email system. P claimed that D’s emails were a trespass to chattel (chattel: a movable or transferable property; personal property; esp., a physical object capable of manual delivery and not the subject matter of real property). P asked the court for an injunction to stop D from emailing P’s employees.
Procedural History: P sued D over trespass to chattel and trail court granted P’s motion for SJ and enjoined D from any future mailings. A divided Court of Appeals affirmed the trails court decision. D appealed the courts ruling enforcing the injunction.
Issue(s): Does an electronic communication sent over an inter-office communication system constitute a trespass to chattel?
Rationale/Reasoning: D’s emailing P’s other employees did not constitute a trespass to chattel because there was no harm. This case differs from the CompuServe case where bulk emails were being where interfering with the computer system/server. This case differs because there was no harm (no resulting problem with the server or the system due to D’s emails). The court rejected P’s claim that D’s emails caused harm because there was no proof that it caused any problems with Intel’s property (i.e. server). If the court had ruled in favor of P, the Californi tort law would be extended beyond its current perimeters.
Judgment: The judgment of the Court of Appeals is reversed.
Dissent/Concurrence: Kennard, concurring. Intel did not show that the bulk emails D sent caused any harm to the computer system or impaired it in any way. Therefore, since there was no damage, there is no trespass to chattel. Kennard questions the implications of trespass to chattel extending to everyday life, such as receiving to many phone calls from a person you do not want to talk to.
Brown, dissenting – There was harm due to the decrease in employee productivity having to deal with D’s massive emailing. D used P’s property to display his email messages. D was intruding on P’s private property.
Evaluation: No trespass to chattel if you cannot show real harm or damage. This ruling broke away from the original courts ruling in Dougherty.