L.W. v. Snap Inc.
Issue
Whether § 230 bars products liability and negligence claims against social media platforms for designing features — including addictive engagement loops, infinite scroll, and content recommendation — that allegedly caused serious psychological harm to minor users.
What Happened
A consolidated group of plaintiffs alleged that Snap, TikTok, Meta, and YouTube designed their platforms to be addictive to minors, leading to anxiety, depression, eating disorders, and self-harm among adolescent users. The plaintiffs framed their claims as products liability cases targeting the platforms' design choices, not as claims arising from user content. The court denied dismissal in substantial part, holding that design defect and negligence claims based on the platforms' own architectural choices were not barred by § 230.
Why It Matters
An important district court application of the post-Lemmon design-defect doctrine to the broader youth mental health litigation against social media platforms. The court's willingness to allow design claims to proceed past a motion to dismiss reflected the growing judicial recognition that § 230 does not immunize all harms that can be traced to social media platform design.
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