Angels spy scandal tests trade secret law limits

Justin Prinstein's firing turns the Angels' so-called spy scandal into a concrete trade secrets question: a scout was seen filming Rockies coaches with a cellphone at Coors Field, and the club moved to terminate him. That is easy to condemn under MLB's conduct rules, but it is not automatically trade secret misappropriation under the DTSA or UTSA. The harder question is whether the material was ever secret in the legal sense, or merely embarrassing to have recorded in public [1].

A rules violation first

The reported facts matter because they separate league discipline from IP liability. Prinstein, known on social media as "The Baseball Spy," was hired by the Angels in December 2025 and fired in late May or early June 2026 after Rockies staff spotted him filming coaches with his cellphone. Then-GM Perry Minasian terminated him, MLB was alerted, and the incident sits squarely in the lane of prohibited electronic sign-stealing conduct [1].

That distinction is not semantic. A club can violate MLB's rules without giving a plaintiff a clean DTSA or UTSA claim. Trade secret law asks a narrower question: was the information not generally known, was it subject to reasonable secrecy measures, and was it misappropriated? Publicly visible coaching signals make that showing difficult before a court ever gets to damages [1].

Why DTSA and UTSA run out of road

The secrecy requirement is where the theory weakens. If the information is visible from the stands, captured by broadcast cameras, or readable by opposing runners and staff in the ballpark, it is hard to call it "not generally known" in the way the federal and state trade secret statutes require. A cellphone makes the observation more aggressive, but it does not transform open observation into protected confidential information.

That is why the closest baseball analogue still points away from trade secret liability. In the Bolsinger litigation, a former Angels pitcher alleged that Astros sign-decoding amounted to trade secret theft, but the case ran into the same visibility problem: the signs themselves were publicly observable, even if the decoding method was objectionable. It is the best comparison here because it tests the same boundary between improper conduct and protected secrecy [2].

The Correa matter shows what the stronger version looks like. Former Cardinals scouting director Chris Correa hacked the Astros' Ground Control database, which was password-protected and proprietary, and the government prosecuted him under the CFAA rather than the DTSA or EEA. He was sentenced to 46 months, and the reported intended loss was $1.7 million. That case is much closer to classic protected-data theft because the information sat behind access controls instead of in the open air of a stadium [3].

The Knicks-Raptors dispute fits the same pattern from a different angle. There, a Knicks employee allegedly transferred more than 3,000 confidential scouting files to Toronto, which looks far more like a conventional trade secret or confidential-information fight than the Prinstein incident. Even so, the matter moved through NBA arbitration under the league constitution, which shows how often sports disputes travel on a contractual track before they ever become federal trade secret cases [4].

What the market thinks the law should cover

The appetite for protection is real, even if doctrine is narrower. A 2017 survey cited in later commentary found that 89.47% of sports team general counsel believed scouting reports were trade secrets, but that figure measures institutional belief, not what a court is likely to recognize. It is also dated, so it should be treated as a snapshot of lawyer sentiment rather than a current statement of legal outcomes [5].

That is the practical gap exposed by the Angels matter. Organizations often want one label that captures anything a rival should not see, but trade secret law is not a general anti-embarrassment statute. Once the information is publicly exposed, the better response is to control conduct through policy and contract, not to ask IP statutes to do work they were never designed to do.

What organizations should document instead

• NDAs that expressly cover scouting materials, device use, and post-employment obligations.
• Device-use rules that limit recording in ballparks, clubhouses, and other high-risk settings.
• Exit interviews and return-of-property checks that focus on files, photos, notes, and cloud access.
• Social-media screening for employees whose public persona can amplify reputational and compliance risk.

Those tools are slower than a headline, but they are enforceable, auditable, and drafted for the real problem. If the information is observational and publicly exposed, the DTSA and UTSA are a poor fit; the organization has to address the risk through rules it can actually enforce.

References

1. Angels scout fired after filming Rockies coaches with cellphone — The Athletic, July 21, 2026
2. Baseball signs and stealing trade secrets — BFV Law
3. NYU JIPEL note on United States v. Correa and trade secret theft in sports — NYU Journal of Intellectual Property & Entertainment Law
4. The NBA secret formula: An analysis of the New York Knicks and Toronto Raptors lawsuit — Sports Litigation Alert
5. Behind the curtain: Trade secret protection and theft in sports — Tangibly