He returned all of the articles he downloaded to JSTOR when he was asked to. He did not distribute them.

UPDATE: Here's JSTOR's confirmation of the above: http://about.jstor.org/statement-swartz

How do you return something that was downloaded?

Since I have slightly trollish inclinations, I emailed JSTOR's customer service after they made that weird announcement about wanting files "returned", expressing my worry over which content was "missing", and when they expected it to be returned and available again. I got a short response claiming the media had misreported the situation:

Thank you for your message. Some of the media details about this incident have been a bit misleading. I can confirm that no content is missing from JSTOR as a result of the recent misuse case. Copies of the files were downloaded from the site, no content is unavailable as a result.

You hand over the physical medium it is stored on and keep no copies.

    > How do you return something that was downloaded?

There was a public gesture where his attorney physically handed over some hard drives. Then the US Secret Service allowed him to access it once in a while to build his defense.

In that case, if the trespassing charge was dropped, what was he being charged with? Sorry, I do not know a lot about this story.

I don't think he had a chance to distribute them, because the high volume of downloading was noticed and they tracked the computer down and then caught him. The plan was certainly to distribute them of he had not been caught, AFAIK.