April 28, 2026·24-1672·3-0·Ryan D. Nelson·By Aisha Johnson
The Ninth Circuit affirmed the dismissal of a class action against Meta Platforms, Inc., holding that Section Two Hundred Thirty of the Communications Decency Act of nineteen ninety-six immunized the company from claims that its platform design and algorithms incited violence against the Rohingya people in Myanmar.
Background
Plaintiffs, members of the Rohingya community, alleged that Meta Platforms, Inc. designed Facebook to encourage anti-Rohingya content that incited violence and genocide in Myanmar. They claimed Meta failed to provide a Burmese-language interface, lacked adequate content moderation, and used algorithms that promoted toxic content to maximize engagement. The district court dismissed the complaint, and the Ninth Circuit reviewed whether Section Two Hundred Thirty of the Communications Decency Act of nineteen ninety-six barred the claims.
The court’s reasoning
The panel held that Section Two Hundred Thirty applies under California choice-of-law rules and that plaintiffs failed to show foreign law should apply. The statute immunizes providers of interactive computer services from being treated as publishers of information provided by others. Meta was an interactive computer service provider, the claims sought to treat Meta as a publisher, and Meta did not materially contribute to the content. Therefore, the claims were barred.
What it means going forward
The decision reinforces broad immunity for online platforms under Section Two Hundred Thirty, even when plaintiffs allege that algorithmic design choices exacerbated real-world violence, and clarifies that federal immunity statutes control over conflicting foreign law claims in diversity cases.
