State of Washington v. Heckel
Washington State Court of Appeals
122 Wash. App. 60 (2004)
Jason Heckel (defendant), an Oregon resident, sent several hundred thousand deceptive unsolicited spam emails weekly promoting a booklet, using misleading subject lines and, according to complaints, sometimes a different domain name than the one identified in the emails; despite being informed by Washington's Attorney General's office about the state's Commercial Electronic Mail Act and that some targeted addresses belonged to Washington residents who'd opted out of spam, Heckel continued his practices unchanged. The state sued, the trial court granted summary judgment for the state, and Heckel appealed.
Whether a state is required to prove that an email spammer knew that some email recipients were residents of the state to prove a violation of an anti-spamming law.