Court Allows Negligence Allegations Against Tech Giants to Proceed

On October 24, 2024, U.S. District Court Judge Yvonne Gonzalez Rogers’ Order entered her order on Defendants’ Motion to Dismiss the School District and Local Government Entities’ Master Complaint In Re: Social Media Adolescent Addiction/Personal Injury Product Liability Litigation MDL No. 3047.  

In response to the defendants’ motion to dismiss, Judge Gonzalez Rogers upheld parts of the school districts’ claims. The court found it plausible that defendants’ actions contributed to worsening mental health among students, leading to predictable costs for school districts to address these issues. 

The court limited some claims under Section 230 and the First Amendment based on prior rulings but did not rule out liability for failing to warn about addiction risks. It found that the “derivative injury” rule did not apply, and plaintiffs sufficiently linked defendants’ actions to increased costs for managing students’ compulsive use of social media. However, Judge Gonzalez Rogers ruled that the claims of damage due to property loss, crime, or threats were not sufficiently supported. 

Judge Gonzales Rogers upheld the duty of care claims and rejected dismissals under the economic loss doctrine for any of the school districts and local government entities involved. A separate ruling will address public nuisance claims.

“This ruling is a powerful step forward in holding these social media giants accountable,” said Levin Papantonio Attorney Emmie Paulos, who serves as a member of the Plaintiff Steering Committee in In re: Social Media Adolescent Addiction/Personal Injury Product Liability Litigation, MDL 3047. 

“For too long, our schools and communities have shouldered the heavy burden of managing the fallout from platforms designed to hook kids, putting profits over young people’s mental health,” Paulos added. “Now is the time to hold these companies accountable for the harm they’ve caused.”  

About the Social Media Addiction MDL

This multidistrict litigation (MDL) involves defendants like Meta Platforms, Inc., Instagram LLC, Snap, Inc., TikTok, Inc., ByteDance, Inc., YouTube LLC, Google LLC, and Alphabet Inc. 

Although Thursday’s Order pertains to actions brought by school districts and local governments, MDL 3047 also comprises personal injury claims brought by individuals. Plaintiffs claim that these companies’ social media platforms are designed to maximize screen time, promoting addictive behaviors in adolescents. This alleged conduct, they argue, leads to serious emotional and physical harm, including fatalities.

As of October 1, 2024, nearly 600 actions are now pending in this MDL, which have been transferred to the U.S. District Court Northern District of California for consolidation of discovery and pretrial matters.

Levin Papantonio is representing school districts that have been picking up the costs of social media addiction in their schools. The law firm’s first such filing occurred in November 2023, on behalf of The School Board of Escambia County, Florida. 

“The youth mental health crisis has bled into every corner of our education system,” said Attorney Jeff Gaddy, a shareholder of Levin Papantonio. “The Defendants’ products are driving unprecedented levels of anxiety and depression in students—leading to poor school performance, increased absences, and even higher risks of substance abuse. 

“The schools we represent in this litigation contend that these ripple effects make it nearly impossible for schools to carry out their core mission of education,” Gaddy added.