Casillas
Casillas v. Berkshire Hathaway Homestate Insurance Co.
Opinion
Opinion
INTRODUCTION
The elements of the tort of trespass to chattels include “injury to the plaintiff’s personal property or legal interest therein.” (Intel Corp. v. Hamidi (2003) 30 Cal.4th 1342, 1348, 1350-1351 (Intel).) In this opinion, we hold appellants Hector Casillas and Adela Gonzalez failed to plead facts satisfying this element in alleging that respondents -- three insurance companies and two investigators -- copied appellants’ electronic litigation files from a third-party computer system, in violation of appellants’ interests in privacy and confidentiality. We conclude appellants failed to
2 allege any actionable injury because: (1) they did not allege damage or disruption to the computer system, as required by Intel; and (2) in any event, they did not allege injury to the copied files or their asserted property interests therein. According to appellants, respondents Berkshire Hathaway Homestate Insurance Company (Berkshire), Cypress Insurance Company (Cypress), Zenith Insurance Company (Zenith), William Reynolds, and Oliver Glover conspired to “hack” a third-party computer system. At the direction of the insurance-company respondents, Reynolds and Glover allegedly copied…