Patterson v. Meta Platforms, Inc.

Issue: Whether New York state law claims against Meta arising from the platform's design and content recommendation features are preempted by § 230(e)(3) or otherwise barred as publisher-based liability.

In a New York state appellate proceeding, plaintiffs brought state law claims against Meta arising from harms caused by Meta's platform design and algorithmic content recommendations. The Appellate Division addressed both § 230(e)(3) preemption and the merits of whether the state law claims were directed at Meta's own conduct or at Meta's publisher function over third-party content.

An important state-court application of § 230 preemption doctrine and the design-defect framework. The New York Appellate Division's analysis contributes to the growing body of state appellate authority on § 230 preemption and is significant for ongoing multi-district litigation against Meta in both state and federal courts.