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UNITED STATES v. GIRARD
United States Court of Appeals, Second Circuit (1979) | 601 F.2d 69
TL;DR: A DEA agent and a former agent were convicted for selling confidential agency records. The court held that intangible information from a government computer system constitutes a "thing of value" under the federal theft statute, 18 U.S.C. § 641.
Legal Significance: This case established that intangible property, specifically confidential government information, is a "thing of value" subject to theft and conversion under 18 U.S.C. § 641. This expanded the statute's application beyond tangible goods to include valuable data and information.