Employees cannot unlawfully delete their computers before handing them back to their employers, according to the Seventh Circuit United States Appeals Court. The decision centres around a case where Jacob Citrin, a former employee of International Airport Centers (IAC), returned a laptop whose contents had been erased with a deletion program. The Court has ruled that Citrin violated the Computer Fraud and Abuse Act by installing a secure delete program.

During his employment, Citrin was tasked with finding suitable real estate locations for IAC to purchase. He was given a laptop to record information. IAC alleges that he started doing his personal business while still employed at IAC. The company had hoped to find some incriminating evidence on the laptop's hard drive, but Citrin had installed and used a secure deletion program to cover his tracks.

Citrin says that his employment contract authorized him to "return or destroy" the data in the laptop, but the court said that he ceased to be protected by that contract when he started doing his own work.
The Court ruled that Citrin's deletion violates the Computer Fraud and Abuse Act because he accessed a protected computer without authorization. He was deemed to have had his authorization ceased when he violated his company's loyalty.