07/10/2026
Recently, the United States Court of Appeals for the Third Circuit vacated the judgment and sentence entered by the United States District Court for the Eastern District of Pennsylvania in United States v. Frances Eddings.
The appeal challenged Ms. Eddings' convictions on four counts of violating the Computer Fraud and Abuse Act (CFAA) and one count of conspiracy. The Third Circuit held that Ms. Eddings did not violate the CFAA by accessing her former employer's computer system after her resignation because there was no evidence that the employer had revoked the authorization granted to her during her employment. The Court concluded that Ms. Eddings' resignation, standing alone, was legally insufficient to establish unauthorized access under the CFAA.
The appeal was briefed and argued by Benjamin Cooper of Daigle Cooper & Associates in Allentown, Pennsylvania. Partner Michael Daigle served as trial counsel, handling the trial and pretrial proceedings, including a motion for judgment of acquittal under Rule 29 of the Federal Rules of Criminal Procedure.
In reaching its decision, the Third Circuit relied extensively on the trial record. The Court found no evidence of any contractual provision, employment policy, or other agreement providing that Ms. Eddings' authorization to access the employer's computer systems automatically terminated upon the end of her employment. The Third Circuit further directed that a Judgment of Acquittal be entered by the trial court in favor of Ms. Eddings.
