PBCBA BAR BULLETINS April 2020 | Page 11

FAMILY LAW CORNER BEWARE OF FEDERAL LIABILITY FOR EMAIL AND SOCIAL MEDIA ADAM RABIN When a couple is going through a divorce, it is common for tensions to run high and emotions to cloud good judgment. Add into the mix a spouse’s concern that the other spouse may be having an affair, hiding assets, or manipulating the couple’s children, and the first spouse (the “snooping spouse”) may feel justified in accessing, without consent, the other spouse’s (the “hacked spouse”) email or social media account. Doing so, however, can expose the snooping spouse to significant federal liability and change the dynamic of the divorce proceedings for the worse. a divorce proceeding will not improve of-evidence letter to the other spouse’s snooping spouse’s litigation position or attorney that demands affirmative steps settlement leverage in the divorce case. be taken to preserve all relevant electronic communications. Another problem arises when the snooping spouse is suddenly forced to defend a new Federal litigation under the Computer federal litigation, increasing the attorney’s Fraud and Abuse Act or the Stored fees and costs that the snooping spouse is Communications Act can be complex both already incurring in the divorce case. The procedurally and substantively. It can snooping spouse also may need to hire a also be expensive. Therefore, if a spouse lawyer with federal court experience to going through a divorce needs to retain defend the federal litigation; it is common an attorney to file or defend a federal that divorce attorneys will not take on litigation arising under these statutes, the a federal litigation because they are spouse should consider an attorney with accustomed to handling divorce cases only experience handling these types of claims The snooping spouse often does not realize in state court. in federal court. that when he or she accesses, without consent, the hacked spouse’s email or The snooping spouse’s unauthorized access social media account, the snooping spouse of the hacked spouse’s account also exposes Adam Rabin is a shareholder with McCabe may be exposed to both civil and criminal the snooping spouse to federal liability Rabin, P.A. and is Florida Bar board certified liability under the federal Computer Fraud for the snooping spouse’s actual damages in business litigation. He handles federal and Abuse Act (18 U.S.C. § 1030) and the or losses, statutory damages, punitive and state court litigation, including claims federal Stored Communications Act (18 damages, and attorney’s fees. 1 Further, arising under the Computer Fraud and U.S.C. § 2701). Additionally, once the not only will the hacked spouse allege Abuse Act and the Stored Communications hacked spouse discovers the snooping these damages, losses and fees against Act. spouse’s unauthorized access of the hacked the snooping spouse within the federal spouse’s account, the threat of federal litigation, but also as a claimed setoff 1 The snooping spouse also may be exposed to liability liability often changes the dynamic of against the snooping spouse’s recovery, if under sections 934.21-28, Florida Statutes, which addresses security of communications and surveillance. the divorce proceeding by giving hacked any, in the divorce case. Notably, section 934.27 provides for attorney’s fees spouse settlement leverage that he or she shifting, the defendant’s profits, and statutory damages otherwise lacked. In fact, upon discovering In addition, the snooping spouse’s in addition to actual damages. that snooping spouse has accessed hacked unauthorized account access often will spouse’s account without permission, it is give the hacked spouse the opportunity now increasingly common for the hacked to change the narrative before the divorce spouse to file a separate lawsuit in federal court, where the snooping spouse now court against the snooping spouse parallel looks like he or she is the one wearing the to the divorce case in state court. “black hat.” This separate federal litigation may create a domino effect of problems for the snooping spouse. First, the snooping spouse’s unauthorized access of hacked spouse’s account may force the snooping spouse to have to admit or deny – in a deposition in the divorce or federal case – whether the snooping spouse accessed the account without the hacked spouse’s consent. Because the unauthorized access also exposes the snooping spouse to criminal liability, this creates a major dilemma as to whether the snooping spouse needs to invoke the 5th Amendment privilege against self-incrimination and consult a criminal defense lawyer. Needless to say, taking the 5th Amendment privilege during In sum, unauthorized hacking into the hacked spouse’s email or social media account exposes the snooping spouse to federal civil and criminal liability, increases attorney’s fees and costs, diminishes settlement leverage, and often causes a negative narrative shift in the divorce. Accordingly, these consequences should belie any notion that the snooping spouse’s accessing of the hacked spouse’s account is a “no harm, no foul” proposition. While it may be difficult for the snooping spouse to resist the temptation, the better and safer approach is for the snooping spouse’s divorce attorney to seek discovery of the hacked spouse’s relevant emails and social media posts, and to send a spoliation- PBCBA BAR BULLETIN 11