Young v. Facebook, Inc.
| Young v. Facebook, Inc. | |
|---|---|
 | |
| Court | United States District Court for the Northern District of California |
| Decided | May 17, 2011 |
| Citation(s) | 790 F. Supp. 2d 1110 |
| Holding | |
| The Court ruled that the social network Facebook was not liable for the alleged violations brought forth by the plaintiff. The court granted Facebook's motion to dismiss the case without leave to amend. | |
| Court membership | |
| Judge(s) sitting | Jeremy Fogel |
| This article is part of a series about |
| Meta Platforms |
|---|
 |
| Products and services |
| People |
| Business |
Young v. Facebook, Inc., 790 F. Supp. 2d 1110, is a
Background
Karen Beth Young of
Young then traveled from Maryland to Facebook's headquarters in California and sought reactivation of her account. In testimony, she stated that she did not receive "human interaction" with a Facebook account representative at Facebook's offices,
Original complaint and motion to dismiss
Young claimed six causes of action in her first complaint against Facebook; a violation of her First Amendment and Fourteenth Amendment rights, a breach of contract, a breach of implied covenant of faith and fair dealing, negligence, and fraud.
Civil rights violation
Young argued that Facebook deprived her of equal protection under the law by terminating her account, and she sought to state this claim under 42 U.S.C. § 1983. She pointed out her disability. She claimed that Facebook was a government actor and acted "under color of state law". She stated that Facebook hosted the profiles of several State and government departments, demonstrating a contract between Facebook and the state.[4]
However, Facebook argued that it was a private entity, and the court agreed, arguing that "Young shows no relationship between Facebook's government contracts and the particular actions that she alleges violated her rights".[2]
Breach of contract
Young referenced Facebook's own statement of rights and responsibilities that forbids users against posting content that is "hateful, threatening, or pornographic; incites violence; or contains nudity"[7] and claimed that Facebook acted in "deliberate indifference to the rights of the Plaintiff".[4]
However, Facebook has long held a policy against any policing of content in its statement of rights and responsibilities.[8] The court agreed and stated "while these provisions place restrictions on users' behavior, they do not create affirmative obligations".[2]
Breach of implied covenant of faith and fair dealing
Young claimed that Facebook broke the implied covenant of good faith and fair dealing by failing to provide the adequate safety services it advertised and by ultimately deactivating the account without "human interaction".[1]
Facebook claimed that it never agreed to provide safety services and that the covenant of good faith could not alter that fact.[6] Furthermore, Facebook was also protected under Section 230 of the Communications Decency Act which provides immunity for internet service providers who publish information generated by third parties.[9]
The court sided with Facebook on this point as well, stating that Facebook had sent Young an email notifying her of the account termination, in accordance with its policies, upholding its contract.[2]
Negligence and Fraud
The plaintiff alleged negligence and fraud on the part of Facebook.[1] However, the court found that the plaintiff did not show that Facebook had a duty on which to base the negligence claim, and that the plaintiff's claim of fraud lacked enough specificity to proceed with legal pleading.[1]
Holding
Given the rationale, Judge Jeremy Fogel of the United States District Court for the Northern District of California granted Facebook's motion to dismiss the claim with leave to amend.[2]
Motion to dismiss amended complaint
The plaintiff amended her complaint to include claims under the Americans with Disabilities Act and related state laws. Facebook moved to dismiss the plaintiff's complaints, and Judge Fogel granted the motion on May 17, 2011,[3] finding that Facebook was not a physical place for the purpose of the Americans with Disabilities Act, "despite its frequent use of terms such as 'posts' and 'walls'". Judge Fogel denied leave to amend.[3]
Reception
Eric Goldman, an internet law professor at Santa Clara University, noted that Section 230 of the Communications Decency Act could well apply to at least some of Young's claims from the second complaint.[3]
See also
- National Federation of the Blind v. Target Corporation
- Ouellette v. Viacom International Inc.
- Lawsuits involving Meta Platforms
References
- ^ a b c d Brown, Evan (November 2, 2010), Facebook victorious in lawsuit brought by kicked-off user
- ^ a b c d e Young v. Facebook, Inc., No. 5:10-cv-03579-JF/PVT (N.D. Cal. 2010).
- ^ a b c d Goldman, Eric (May 9, 2011), Facebook User Loses Lawsuit Over Account Termination—Young v. Facebook
- ^ a b c d e f Young v. Facebook Original Complaint, (N.D. Ca. 2010).
- ^ a b c Hill, Kashmir (September 1, 2010), "Maryland Woman Sues After Being Banned by Facebook", Forbes
- ^ a b Motion to Dismiss by Facebook.
- ^ Murphy, Pat (November 11, 2010), "Law Life: Unruly 'friend' gets Facebook death penalty", Forbes
- ^ "Facebook's Statement of Rights and Responsibilities"
- ^ "47 U.S.C. § 230"