9th Cir.;
14-10283

The court of appeals affirmed a district court order granting a judgment of acquittal. The court held that evidence was insufficient to prove obstruction of justice where it failed to show that the defendant, who allegedly wiped the free space of computer hard drives to eliminate incriminating emails, actually deleted electronic records or files. The court held further that the defendant did not unlawfully “conceal” emails by moving them from an email application’s inbox to its deleted items folder.