Estate of Bride v. Yolo Technologies, Inc.

Issue: Whether § 230 bars wrongful death claims against Yolo based on design-defect theories targeting Yolo's anonymity features, and on assumption-of-duty theories arising from Yolo's promises in its terms of service to prevent cyberbullying.

Carson Bride, a teenager, died by suicide after receiving cyberbullying messages on Yolo, an anonymous messaging app. His estate sued Yolo on two theories: (1) products liability — Yolo negligently designed its anonymity features, which enabled cyberbullying while preventing victims from identifying perpetrators; and (2) assumption of duty under Barnes v. Yahoo! — Yolo promised in its Terms of Service to prevent cyberbullying, incurring an independent duty of care it then failed to fulfill. The Ninth Circuit reversed dismissal on both theories, holding that the design-defect claim targeted Yolo's own product choices (not third-party content) and that Yolo's ToS promise could give rise to an actionable duty under Barnes.

Extended both the Lemmon design-defect framework and the Barnes assumption-of-duty doctrine in the same case. Established that a platform's contractual promises to users about safety features — even in standard ToS language — can give rise to an independent duty of care that § 230 does not preempt. A leading case in the § 230 litigation over anonymous messaging apps and cyberbullying-related youth harms.