Bride v. Snap, Inc.

Issue: Whether § 230 bars wrongful death claims against Snap arising from Snapchat's design features — including its anonymous messaging and ephemeral content features — allegedly used to facilitate drug trafficking that resulted in a teenager's death.

The parents of Carson Bride, a teenage boy who died after purchasing fentanyl-laced pills through Snapchat, sued Snap under products liability and negligence theories. They argued that Snapchat's design — including its ephemeral messaging, location features, and the ease with which drug dealers could target minors — constituted negligent design independent of the content of the messages transmitted. The district court denied dismissal in part, holding that design defect claims targeting Snap's own product architecture did not treat Snap as the publisher of user-generated content and were therefore not barred by § 230, consistent with Lemmon v. Snap.

A significant application of the Lemmon design-defect framework to the fentanyl trafficking epidemic on social media platforms. Part of a growing body of litigation testing whether the Lemmon exception is limited to specific features like speed filters or extends broadly to platform design choices that facilitate offline criminal conduct. The case contributed to the litigation that eventually produced Estate of Bride v. Yolo Technologies in the Ninth Circuit.