Cyber-Espionage Hits Major League Baseball: A review of the Cardinals & Chris Correa case

When one thinks of cyber-espionage, images abound of young people with iridescent faces from the glow of computer screens, listening to metal music, and living in their parents’ basement hacking into banks and public systems for thrill, notoriety, and (sometimes) money. Such images are, of course, clichés. 

Take Chris Correa: a well-educated baseball outsider in his thirties, who at one time was a doctoral candidate at the University of Michigan and who swiftly rose within the ranks of the St. Louis Cardinals’ front office to become its Scouting Director in late 2014.[1] In 2016, Correa admitted to engaging in cyber-espionage against the Astros, pleading guilty to five counts of federal unauthorized access of a protected computer in violation of 18 U.S.C. 1030(a)(2)(C) & (c)(2)(B)(iii).[2] Then, in January 2017, after concluding his investigation of Correa’s conduct, Major League Baseball (MLB) Commissioner Robert D. Manfred, Jr. banned Correa from the MLB, stripped the Cardinals of their top two 2017 draft picks (awarding them to the Astros), and ordered the Cardinals to pay the Astros $2 million.[3]

This article reviews the Correa case, specifically:

• the facts;
  
  
• the MLB Commissioner’s powers;
  
  
• the decision; and
  
  
• author’s analysis.