Intel Corp. v. Hamidi

"Intel Corp. v. Hamidi", 30 Cal. 4th 1342 (2003), is a decision of the California Supreme Court. In "Hamidi" the California Supreme Court held that a former Intel employee's e-mails to current Intel employees, despite requests by Intel to stop sending messages, did not constitute trespass of Intel's e-mail system.

Kourosh Kenneth Hamidi was a former Intel employee who sent e-mails to criticizing Intel to current Intel employees. Because the messages caused discussion among employees, Intel asserted that these communications constitute trespass to chattels under California law. The trial court agreed and enjoined Hamidi from sending additional e-mails. Hamidi appealed his decision to the court of Appeal, which affirmed the trial court's decision. The California Supreme Court, by a vote of 4-3, reversed.

The decision was notable because the Court declined to extend common law trespass claims to the computer context, absent actual damage. As the court stated:

Intel's claim fails not because e-mail transmitted through the Internet enjoys unique immunity, but because the trespass to chattels tort--unlike the causes of action just mentioned--may not, in California, be proved without evidence of an injury to the plaintiff's personal property or legal interest therein.

. . .

In the present case, the claimed injury is located in the disruption or distraction caused to recipients by the contents of the e-mail messages, an injury entirely separate from, and not directly affecting, the possession or value of personal property. [Intel Corp. v. Hamidi, 30 Cal. 4th 1342, 1347-48 (Cal. 2003)]

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