M.P. v. Meta Platforms, Inc.

Issue: Whether § 230 bars claims that Meta's recommendation algorithms and design features facilitated the sexual exploitation of a minor by connecting the minor with an adult abuser on Instagram.

The Fourth Circuit addressed claims brought on behalf of a minor who was contacted through Instagram by an adult who subsequently engaged in sexual exploitation. The plaintiffs argued that Meta's recommendation system and design choices — including features that enabled adults to contact minors — constituted Meta's own independent conduct outside § 230's protection. The Fourth Circuit analyzed the scope of § 230 in the context of child sexual exploitation claims and the application of the post-Lemmon design-defect framework.

An important Fourth Circuit decision on § 230 in the child sexual exploitation context, adding to the developing circuit-level body of law on whether design-defect theories and algorithm-based claims survive § 230 dismissal. The decision is significant for the wave of CSAM and child exploitation litigation against social media platforms pending in multiple circuits.