Deman Data Systems, LLC v. Schessel, 2014 WL 408443 (M.D. Fla. Feb. 3, 2014)

Deman Data Systems, LLC v. Schessel, 2014 WL 408443 (M.D. Fla. Feb. 3, 2014)

How far does a CFAA claim’s supplemental jurisdiction over state law claims extend?

A federal court has non-exclusive federal question subject matter jurisdiction over 18 U.S.C. § 1030 Computer Fraud and Abuse Act claims and supplemental jurisdiction over all state claims which arise out of a common nucleus of operative fact with the CFAA claim. How far does this supplemental jurisdiction extend?

Where a CFAA claim is premised on a former employee’s wrongful access to his employer’s computer servers to obtain confidential information and customer information to use to compete with the former employer, all claims arising out of the dispute stemming from the employment relationship are within the court’s supplemental jurisdiction.

• The court had supplemental jurisdiction over both parties claims and counterclaims for tortious interference and defamation, former employer’s claims for breach of contract, civil theft and fraud, and former employee’s claim for unpaid wages because they arose out of the dispute stemming from the employment relationship.
• The court did not have supplemental jurisdiction over the former employee’s unjust enrichment claim which sought reimbursement for travel expenses because such travel expenses did not arise out of the dispute stemming from the employment relationship, that is, a common nucleus of operative fact with the CFAA claim.

Deman Data Systems, LLC v. Schessel, 2014 WL 408443 (M.D. Fla. Feb. 3, 2014).