Doe v. Reddit, Inc.
U.S. Court of Appeals for the Ninth Circuit (on appeal from C.D. Cal.)
- Court
- U.S. Court of Appeals for the Ninth Circuit (on appeal from C.D. Cal.)
- Docket
- No. 21-56293 (9th Cir.); No. 8:21-cv-00768 (C.D. Cal.)
- Parties
- Jane and John Doe plaintiffs (CSAM/NCII survivors), on behalf of a putative class, vs. Reddit, Inc.
- Claim type
- section230
- Filed
- 2021-04-22
- Outcome
- District court dismissed with prejudice (Oct. 28, 2021) on Section 230 grounds; the Ninth Circuit affirmed Oct. 24, 2022, holding FOSTA's sex-trafficking exception to Section 230 requires plausibly alleging the website's own conduct violated 18 U.S.C. 1591; the U.S. Supreme Court denied certiorari May 30, 2023.
Summary
A pseudonymous plaintiff alleged that an abusive ex-partner repeatedly posted non-consensual sexual images and videos of her (some taken when she was a minor) across dozens of subreddits, and that Reddit was slow to remove the content and profited from it, asserting civil child sex-trafficking claims under the TVPRA. The district court dismissed the suit as barred by Section 230 of the Communications Decency Act. The Ninth Circuit affirmed, reading FOSTA's exception to Section 230 narrowly: a plaintiff must plausibly allege that the platform's own conduct, not merely its users' conduct, knowingly violated the federal sex-trafficking statute. Allegations that Reddit turned a blind eye to user content were held insufficient. The Supreme Court later declined to review the decision.
Related issue
Sources
- 01
- 02FindLaw - Does v. Reddit Inc (2022), No. 21-56293Court / Legal
- 03
- 04