Kinslow v. State

860 S.E.2d 444, 311 Ga. 768
CourtSupreme Court of Georgia
DecidedJune 21, 2021
DocketS20G1001
StatusPublished
Cited by9 cases

This text of 860 S.E.2d 444 (Kinslow v. State) is published on Counsel Stack Legal Research, covering Supreme Court of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kinslow v. State, 860 S.E.2d 444, 311 Ga. 768 (Ga. 2021).

Opinion

311 Ga. 768 FINAL COPY

S20G1001. KINSLOW v. THE STATE.

PETERSON, Justice.

Jereno Sadatrice Kinslow appeals his felony conviction for

computer trespass in violation of OCGA § 16-9-93 (b) (2). The

conviction is premised on evidence that Kinslow altered his

employer’s computer network settings so that e-mail messages

meant for Kinslow’s boss would also be copied and forwarded to

Kinslow’s personal e-mail account. The Court of Appeals affirmed

Kinslow’s conviction, and we granted Kinslow’s petition for

certiorari, posing the question of whether Kinslow’s conduct

constituted a violation of OCGA § 16-9-93 (b) (2). Although the

statute in general is extremely broad, the portion of (b) (2) on which

the State exclusively relies does not reach Kinslow’s conduct.

Accordingly, we conclude that the evidence presented at Kinslow’s

trial was insufficient to support his conviction under Jackson v. Virginia, 443 U.S. 307 (99 SCt 2781, 61 LE2d 560) (1979), and we

reverse.

Viewed in the light most favorable to the verdict, the evidence

presented at trial shows that, in 2013, Kinslow was an information

technology (“IT”) employee of the City of Norcross (“the City”). In

October 2013, Greg Cothran was hired to manage the IT

department, with an objective to increase the reliability and

efficiency of the City’s computer system. Shortly after Cothran

started his new position, he began having difficulties with Kinslow.

In November 2013, Cothran criticized Kinslow’s work performance,

which led to an argument and a loud outburst from Kinslow. Due to

Kinslow’s behavior, Cothran became concerned that Kinslow might

damage the City’s computer network. As a result, Cothran

attempted to place certain safety measures on the system, and

Kinslow’s employment was eventually terminated in June 2014.

In August 2014, Monique Lang, the City Clerk, sent an e-mail

from her work account to Cothran at his work account. Lang

addressed this message solely to Cothran. In response, Lang

2 received a “bounce-back” e-mail notification stating, in relevant

part, that Lang’s e-mail was undeliverable to a recipient with an

“@me.com” e-mail address. Lang alerted Cothran about this

occurrence, and subsequent investigation revealed that the

@me.com e-mail address was a personal account that had been

established by Kinslow. The City also discovered that the City’s

computer network settings had been altered by checking a box in the

City’s computer program to cause Cothran’s incoming e-mail

messages to be copied and forwarded to Kinslow’s personal @me.com

account. The forwarding of Cothran’s e-mail messages began in

approximately December 2013, while Kinslow was still employed by

the City. At that time, only Cothran and Kinslow had the necessary

“administrator-level access” to alter the settings in order to forward

Cothran’s incoming e-mails. This forwarding continued until it was

discovered in August 2014, two months after Kinslow’s termination.

Evidence indicates that Kinslow routinely accessed the @me.com

account from his cell phone prior to discovery by the City.

At the end of a jury trial, Kinslow was found guilty of one count

3 of violating OCGA § 16-9-93 (b) (2) and sentenced to ten years of

probation. The Court of Appeals affirmed. See Kinslow v. State, 353

Ga. App. 839 (839 SE2d 660) (2020). The only question before this

Court is whether the evidence presented at trial supported

Kinslow’s conviction for computer trespass under OCGA § 16-9-93

(b) (2).1

When we consider whether the evidence [was] legally sufficient to sustain a conviction under Jackson, we view the evidence in the light most favorable to the verdict, draw every reasonable inference from the evidence that is favorable to the verdict, ignore any conflicts or inconsistencies in the evidence, assume that the jury reasonably believed every word of testimony favorable to the verdict and reasonably disbelieved every word unfavorable to it, and only then inquire whether any reasonable person could conclude that the State has proved the guilt of the accused beyond a reasonable doubt.

Debelbot v. State, 308 Ga. 165, 168 n.6 (839 SE2d 513) (2020) (citing

Jackson, 443 U.S. at 319).

1 The Court of Appeals concluded that Kinslow’s challenge to the accusation was not properly before that court, as he did not file a general demurrer or a motion in arrest of judgment. See Kinslow, 353 Ga. App. at 841 (1). That court also concluded that the trial evidence was sufficient under Jackson. See id. at 842-843 (2). We granted certiorari only as to the Court of Appeals’s determination that the evidence was sufficient, and this opinion addresses only that issue. 4 OCGA § 16-9-93 (b) (2) defines the offense of computer

trespass, in relevant part, as “us[ing] a computer or computer

network with knowledge that such use is without authority and with

the intention of . . . [o]bstructing, interrupting, or in any way

interfering with the use of a computer program or data[.]” Kinslow

was charged with committing computer trespass by “us[ing] a

computer network with knowledge that such use was without

authority and with the intention of obstructing and interfering with

data from a computer, by copying Greg Cothran’s emails and causing

them to be forwarded to his own private email account.” The State

thus was required to prove that Kinslow used a computer network

knowingly without authority with the intention of obstructing or

interfering with the use of data.2 We conclude that the evidence

2 The trial court gave the jury an instruction broader than the basis on

which Kinslow was charged in the accusation:

I charge you that a person commits the offense of computer trespass when such person uses a computer or computer network with knowledge that such use is without authority and with the intention of: deleting or in any way removing, either temporarily or permanently, any computer program or data from a computer or a computer network; or obstructing, interrupting, or in any way

5 presented at trial was insufficient to prove that Kinslow’s use was

done with the intention of obstructing or interfering with the use of

data.3

interfering with the use of a computer program or data; or altering, damaging, or in any way causing the malfunction of a computer, computer network, or a computer program, regardless of how long the alteration, damage, or malfunction persists.

The State in its brief to this Court, however, expressly waived any reliance on the “computer program” language in the “use of a computer program or data” phrase of the statute. While we are not bound by such a concession, see Holt v. Ebinger, 303 Ga. 804, 808 n.3 (814 SE2d 298) (2018), we choose to accept it here, particularly given the potential due process concerns involved in convicting a defendant on a ground not charged in the accusation. See Pippen v. State, 299 Ga.

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860 S.E.2d 444, 311 Ga. 768, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kinslow-v-state-ga-2021.