A Los Angeles jury found Meta and YouTube liable for a teen's addiction to their platforms in March; a state court judge upheld the verdict in June. Now Meta is taking the case to the California Court of Appeal, with its legal strategy hinging on Section 230 and the First Amendment.

Meta filed a notice of appeal in Los Angeles County Superior Court, seeking to overturn a jury verdict holding the company liable for a young woman's social media addiction — a finding a state court judge had already refused to discard on June 10.

The case is P.F., et al. v. Meta Platforms, Inc., et al. (case no. 23SMCV03371). The jury reached its verdict on March 25, awarding plaintiff K.G.M. — identified in court by her first name, Kaley — $3 million in compensatory damages, with jurors recommending an additional $3 million in punitive damages, for a combined $6 million exposure. The jury assigned Meta 70% of the liability and co-defendant YouTube 30%. After nine days of deliberations across a seven-week trial, the jury found that specific platform design features — infinite scroll, autoplay, filters, and push notifications — were a "substantial factor" in Kaley's depression, anxiety, and body dysmorphia, per Law.com.

Judge Carolyn B. Kuhl's June 10 ruling denying Meta and YouTube's post-trial motions for judgment notwithstanding the verdict closed the last procedural off-ramp short of a full appeal. "There was substantial evidence that plaintiff was harmed by the design features of Instagram, regardless of any of the content found on that platform," Kuhl wrote, per Law.com. She also found, per Law.com, that Meta had failed to warn users despite internal knowledge of risks to minors.

Meta's appeal centers on Section 230 of the Communications Decency Act and First Amendment protections. Mark Mosier of Covington & Burling, Meta's appellate counsel, argued at the post-trial stage that choices like infinite scroll and autoplay are content-dissemination decisions and therefore shielded from liability. "The plaintiffs' legal theory attempts to improperly circumvent Section 230 and the First Amendment, and we expect this ruling to be overturned on appeal," a Meta spokesperson said following Kuhl's June 10 ruling, per Law.com. A separate Meta statement, offered at verdict and repeated this week, held that teen mental health is "profoundly complex and cannot be linked to a single app."

Section 230 has been a reliable platform defense for two decades. Kuhl's ruling is distinct: she found that design architecture — how a feed is weighted, how long autoplay extends a session — is separable from content decisions and potentially outside Section 230's scope. The California Court of Appeal hasn't weighed in on that question. Its answer carries stakes beyond this case: the parallel federal MDL, In re: Social Media Adolescent Addiction/Personal Injury Products Liability Litigation (4:22-md-03047-YGR), consolidates hundreds of similar suits before Judge Yvonne Gonzalez Rogers in the Northern District of California.

YouTube also intends to appeal. José Castañeda, a spokesperson for Google, called the filings "standard motions for this case to move forward," per ABC News. Lead plaintiff's attorney W. Mark Lanier said his team expects the appellate court to "continue the careful application of the law to this case, affirming the verdict of the trial court," per ABC News.

Three things remain unsettled: the appellate briefing schedule has not been set publicly; the $3 million punitive damages figure is still a jury recommendation pending final judicial determination; and the California appellate courts have yet to rule on whether the design-features carve-out from Section 230 holds — an answer that will reverberate through the broader litigation stack.