MatrixCare Inc. v. Netsmart Technologies, Inc.
- Michael Davis
- 0:19-cv-01684
- U.S. District Court · District of Minnesota
- 3
In MatrixCare v. Netsmart, Judge Davis denied MatrixCare’s temporary restraining order because it lacked enough evidence of unauthorized, fraudulent computer access.
The order directly affected MatrixCare Inc.’s request for a temporary restraining order by denying it. The opinion does not state a final disposition of the case.
What happened
MatrixCare Inc. v. Netsmart Technologies, Inc. concerned MatrixCare’s request for a temporary restraining order and its objections to a magistrate judge’s recommendation. The recommendation addressed whether MatrixCare could pursue a claim under the Computer Fraud and Abuse Act.
The court changed one part of the recommendation, declining to decide whether the statute provides a private right to sue for the alleged violation. Even assuming such a right exists, the court said MatrixCare had not shown evidence that the alleged computer access was unauthorized or exceeded authority and was done knowingly with intent to defraud.
Judge Michael J. Davis adopted the recommendation as modified and denied MatrixCare’s motion for a temporary restraining order.
The detailed version
- MatrixCare Inc. v. Netsmart Technologies, Inc. · No. 0:19-cv-01684
- Michael Davis
- July 30, 2019
Background
MatrixCare Inc. moved for a temporary restraining order against Netsmart Technologies, Inc. Magistrate Judge Becky R. Thorson issued a Report and Recommendation dated July 12, 2019, and MatrixCare filed objections.
Court’s analysis
The district court conducted a de novo review, meaning it independently reviewed the relevant portions of the record. It declined to adopt the recommendation’s statement that MatrixCare had not established a private right of action under 18 U.S.C. § 1030(a)(4), a provision of the Computer Fraud and Abuse Act. The court said it did not need to decide at that time whether the 2008 amendment to the Act created such a right, assuming that a private right of action exists when the statutory requirements are met.
The court explained that § 1030(a)(4) requires unauthorized computer access to be undertaken knowingly and with intent to defraud. It agreed, however, that MatrixCare had not shown evidence supporting a finding that the alleged access was unauthorized or exceeded authorized access and was done knowingly with intent to defraud.
Disposition
The court adopted Magistrate Judge Thorson’s Report and Recommendation as modified. Judge Michael J. Davis denied MatrixCare’s motion for a temporary restraining order.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.