Federal Court Dismisses ADA and Content Moderation Suit Against Meta

On November 4, 2025, the U.S. District Court for the Northern District of California issued an order granting a motion by Meta Platforms, Inc. to dismiss a First Amended Complaint filed by a self-represented plaintiff. The lawsuit centered on allegations that Meta suspended or restricted the plaintiff's Facebook account, interfering with his ability to promote his business and interact with prospective clients via Marketplace and Buy/Sell Groups.

The plaintiff brought 22 separate claims against Meta, covering statutory civil rights, digital accessibility, privacy, contract law, and antitrust allegations. The court dismissed the entire complaint, allowing only four specific claims to be amended.

Digital Accessibility and Title III of the ADA

Among the claims was an allegation that Meta violated Title III of the Americans with Disabilities Act (ADA) due to an asserted lack of screen reader compatibility and absence of necessary accommodations on Facebook Marketplace.

To establish a Title III claim, a plaintiff must show disability status, that the defendant operates a place of public accommodation, and that access was denied because of disability. In the Ninth Circuit, established precedent requires a nexus between the challenged service and an actual physical location. Citing Weyer v. Twentieth Century Fox Film Corp. and Lloyd v. Facebook, Inc., the district court ruled that Facebook Marketplace is not a "place of public accommodation" under the ADA because it is not a physical venue. Consequently, the court dismissed the ADA count with prejudice, denying leave to amend.

Section 230 and Contractual Liability Limits

The court determined that the core grievances involving account bans, restrictions, and Meta's handling of third-party content fell under Section 230(c)(1) of the Communications Decency Act. Because Meta qualifies as an interactive computer service provider, the disputed posts originated from third parties, and the claims treated Meta as a publisher or speaker, Section 230 barred counts involving account moderation, defamation, emotional distress, fair housing, and related claims without leave to amend.

Additionally, the court took judicial notice of Meta's Terms of Service. It found that the platform's "as is" warranties, disclaimers regarding user-generated content, and explicit limits precluding consequential damages and lost profits barred numerous causes of action, including claims for breach of contract, negligence, and cybersecurity issues.

Remaining Claims and Next Steps

The court also dismissed without leave to amend claims brought under the Fourth Amendment, 42 U.S.C. § 1983, and the Freedom of Information Act (FOIA), noting that Meta is a private entity rather than a government actor or federal agency.

However, the court granted limited leave to amend for four counts:

• Invasion of privacy (intrusion upon seclusion);
• Antitrust claims under the Sherman and Clayton Acts;
• Conspiracy claims under 42 U.S.C. § 1985 only; and
• Intellectual property claims regarding written messages used for AI training.

The plaintiff was ordered to file any Second Amended Complaint by December 5, 2025, without adding new substantive counts or defendants. Full details are available in the official court ruling.