MICHAEL ANTHONY JOHNSON v. STATE OF MARYLAND
Court of Special Appeals, Woodward, May 31, 2016,
E-Mail Harassment – CR 3-805 – While the unit of prosecution for e-mail harassment is “course of conduct,” it is possible to be convicted of numerous courses of conduct over various days (here 10 counts for 10 “courses of conduct” on each of 10 days).

Violation of Protective Order – 50 counts did not merge under rule of lenity because “the verdict sheet, coupled with the trial court’s instructions regarding the verdict sheet and the prosecutor’s closing argument, made clear that each violation of the protective order corresponded to each email sent by appellant to Williams.”

A question regarding e-mail authentication was also answered, but the defendant admitted that the e-mails were sent from his account, so that made it a bit easier. Donati, cited and quoted by the Court here, provides a better look at the issue (MDCrime breakdown here).