The key litigated issue before the US Court of Appeals for the Ninth Circuit in Sams v. Yahoo! Inc. was whether Yahoo! qualified for immunity under section 2707(e) of the Stored Communications Act when Yahoo! produced basic subscriber information to the government in response to allegedly invalid subpoenas. Section 2707(e) immunizes network service providers from liability for disclosing basic subscriber information to the government in good faith reliance on a grand jury subpoena. In particular, the question before the Ninth Circuit was whether Yahoo!'s actions met section 2707(e)'s standard for good faith reliance.

In December 2008, Yahoo! received faxes of two grand jury subpoenas from the District Attorney's Office for the Southern Judicial Circuit of Georgia. The subpoenas requested that Yahoo! disclose records about the identification of one of its users and produce additional documents. Yahoo! produced the requested information. Sams then filed a class action purporting to represent a class of plaintiffs whose information Yahoo! had allegedly disclosed to law enforcement in violation of the SCA. In 2011, Yahoo! moved to dismiss Sams's complaint. The US District Court for the Northern District of California granted Yahoo!'s motion to dismiss, finding that Yahoo! was statutorily immune under section 2703(e) of the SCA. Sams appealed the district court's dismissal.

In its April 15, 2013 opinion, the US Court of Appeals for the Ninth Circuit affirmed the US District Court for the Northern District of California's dismissal and held that Yahoo! was immune from Sams's claims that Yahoo! violated the SCA when it disclosed her subscriber information to the government under allegedly invalid subpoenas. The court held that Yahoo! qualified for immunity under section 2707(e) of the SCA, which shields network service providers from suit if they disclose basic subscriber information to the government in good faith reliance on a grand jury subpoena.

Addressing the meaning of "good faith reliance" under section 2707(e) as a matter of first impression, the Ninth Circuit held that the test for good faith reliance has both objective and subjective elements, and that the test is met when both:

The Ninth Circuit cautioned that actual knowledge that a subpoena, or other process, is invalid under the applicable law would prevent the defense from applying.

In applying this test, the Ninth Circuit found that Yahoo! qualified for immunity because:

Parties litigating before the Ninth Circuit should take note that this case establishes that the good faith reliance defense features both an objective and a subjective element, and that the defense is met when a defendant complies with a subpoena that appears valid on its face, in the absence of any indication of irregularity sufficient to put the defendant on notice that the subpoena may be invalid or contrary to applicable law. The Ninth Circuit stated in dicta that even if the subpoenas were ultimately found to be invalid, the good faith reliance defense would still apply because the subpoenas bore all of the indicia of lawful authority.