In a recent decision, a federal court in California found it unlawful for an employer to monitor an employee’s key strokes in order to obtain his password to a personal email account. The U.S. district court found this action violated the Electronic Communications Privacy Act, passed in 1986. The decision, Brahmana v. Lembo, is important. While the email account may be personal, the equipment used to access the account belongs to the employer. The courts have wrestled with this issue for some time and will, no doubt, continue to struggle with he boundaries between employee property and employer property.