Section 230 Other

People of the State of California v. Meta Platforms, Inc.

🏛 U.S. District Court for the Northern District of California · 📅 2023-10-24

Issue

In *People of California v. Meta Platforms*, the State Attorneys General argue that Section 230 of the Communications Decency Act does not immunize Meta from state consumer protection claims targeting the company's own design choices and business practices — as opposed to its role in publishing third-party content. The question is legally contested because Section 230(e)(3) expressly preempts state laws "inconsistent with" its immunity provisions, and the Ninth Circuit has historically read that bar broadly, leaving unresolved how far it extends to claims framed around a platform's independent conduct rather than its editorial functions.

What Happened

Days before a scheduled April 15, 2026 hearing on Meta's pending Motion for Summary Judgment, the Attorneys General of California, Colorado, Kentucky, and New Jersey filed a Statement of Recent Decision pursuant to Civil Local Rule 7-3(d)(2), submitting as Exhibit A the Massachusetts Supreme Judicial Court's April 10, 2026 opinion in *Commonwealth v. Meta Platforms, Inc.*, No. SJC-13747. The filing is a procedural notice, not a substantive brief, and contains no quotation or textual analysis of the SJC opinion — the opinion itself is attached and left to speak. Plaintiffs' position is that the SJC, a court of last resort, held that Section 230 does not bar state consumer protection claims against Meta, and that this ruling constitutes directly on-point persuasive authority the MDL court should consider when ruling on Meta's summary judgment motion. The filing asks for no independent relief; it asks only that the Court take notice of the opinion.

Why It Matters

Meta's central defense at summary judgment is that Section 230 extinguishes the states' consumer protection claims before they can reach a jury, on the theory that those claims would effectively hold Meta liable as a publisher of harmful user-generated content. The Massachusetts Supreme Court — one of the most respected state courts of last resort in the country — just rejected that argument in a case involving the same defendant and a structurally similar legal theory, and Plaintiffs are placing that ruling before the MDL judge at the earliest opportunity. Whether it moves the needle depends on how closely the Massachusetts claims and pleadings track those at issue in the MDL, a question the filing conspicuously leaves unaddressed and that Meta will almost certainly contest. The filing also signals a deliberate multi-forum strategy by the state AGs: collecting appellate-level authority across jurisdictions to build persuasive momentum against Section 230 preemption — a campaign worth watching as similar litigation proceeds in other states.

Related Filings

Other proceedings in the same litigation tracked by this monitor.