Neville v. Snap, Inc.

Issue: Whether § 230 bars California state law products liability and negligence claims against Snap for design features that allegedly facilitated the drug trafficking death of a minor.

Plaintiffs, the parents of a minor who died after purchasing fentanyl through Snapchat, alleged that Snap's design choices — including its ephemeral messaging, maps feature, and ease of anonymous account creation — made the platform an attractive and effective venue for drug trafficking. The Los Angeles Superior Court overruled Snap's demurrer, holding that the design defect claims under California law targeted Snap's own product architecture and were not barred by § 230.

A California state court application of the Lemmon / design-defect framework in the context of the fentanyl crisis. Part of the wave of state court litigation applying design-defect theories to social media features in cases involving drug trafficking and minor victims.