Baldwin Kennedy v. Meta Platforms, Inc.

CourtDistrict Court, N.D. California
DecidedOctober 23, 2024
Docket4:23-cv-06615
StatusUnknown

This text of Baldwin Kennedy v. Meta Platforms, Inc. (Baldwin Kennedy v. Meta Platforms, Inc.) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Baldwin Kennedy v. Meta Platforms, Inc., (N.D. Cal. 2024).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 RONDA BALDWIN KENNEDY, et al., Case No. 23-cv-06615-HSG

8 Plaintiffs, ORDER GRANTING MOTION TO DISMISS 9 v. Re: Dkt. No. 15 10 META PLATFORMS INC., et al., 11 Defendants.

12 13 Pending before the Court is Defendant Meta Platforms Inc.’s motion to dismiss. Dkt. No. 14 15. The Court finds this matter appropriate for disposition without oral argument and the matter is 15 deemed submitted. See Civil L.R. 7-1(b). For the reasons detailed below, the Court GRANTS the 16 motion. 17 I. BACKGROUND 18 Pro se Plaintiff Ronda Baldwin-Kennedy and two of her political campaign entities1 19 initially filed this case in the District of Nevada against Defendants Meta Platforms, Inc., Hoang 20 Hai Mobile, and several unidentified “Doe” Defendants.2 See Dkt. No. 1 (“Compl.”). The parties 21 stipulated to transfer the case here. Dkt. Nos. 18–20. 22 Plaintiff Baldwin-Kennedy alleges that Hoang Hai Mobile and Does 1–10 gained 23 unauthorized access to her Facebook account, including Facebook Pages that she maintained for 24 1 The complaint names Plaintiff Baldwin-Kennedy’s campaign committees—Ronda Kennedy for 25 Senate and Ronda Kennedy for Congress 2020—as separate plaintiffs. However, the complaint also appears to acknowledge that the Facebook and Instagram accounts at issue in this case are 26 Plaintiff Baldwin-Kennedy’s. See Compl. at ¶¶ 1, 16–20, 43–45, 48. The Court therefore need not consider whether certain arguments apply to some but not all Plaintiffs. 27 2 As noted below, Defendant Hoang Hai Mobile has not appeared in this case and Plaintiff has not 1 her political campaign, and successfully locked her out of her own account. See Compl.at ¶¶ 1–2, 2 16–20. Plaintiff alleges that she reached out to Defendant for assistance, but it has still not helped 3 her restore her account. See id. at ¶¶ 4, 21–22, 24. Plaintiff contends that Defendant, which owns 4 the Facebook and Instagram services, is liable for the third-party breach as well as the delay in 5 restoring access to her account. See, e.g., id. at ¶¶ 12, 23–44. 6 Additionally, Plaintiff alleges that Defendant has denied her request to “verify” her 7 Instagram account, which still remains under her control, with a “Blue Checkmark of 8 Verification.” See id. at ¶¶ 45–46. As the parties appear to agree, such a “checkmark” or “badge” 9 confirms that an account is the authentic Instagram presence for that person or brand. See Dkt. 10 No. 15 at 2, & n.1. Plaintiff contends that Defendant has denied this verification for racially 11 discriminatory reasons. Specifically, Plaintiff asserts that Defendant has engaged in election 12 interference and violated Title II of the Civil Rights Act of 1964 by “not allowing the only Black 13 Candidate for U.S. Senate in Nevada a blue checkmark for verification but allowing her [] white 14 opponents to have a Blue Checkmark.” Id. at ¶ 48. As a result, Plaintiff states that her campaign 15 page appears less legitimate than her opponents, leading to less support and fewer donations. Id. 16 at ¶ 46. 17 Based on these allegations, Plaintiff brings multiple causes of action. See id. at ¶¶ 23–55. 18 She alleges that the loss of access to Facebook and the denial of the Instagram verification have 19 harmed her electoral chances in her ongoing political campaign, and claim that Defendants are 20 liable for $300,000 in connection with unspecified “injur[ies] in its business and property” and for 21 $1 million in punitive damages. See id. at ¶¶ 64–72. Defendant has moved to dismiss the 22 complaint in its entirety. Dkt. No. 15. 23 II. LEGAL STANDARD 24 Federal Rule of Civil Procedure 8(a) requires that a complaint contain “a short and plain 25 statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). A 26 defendant may move to dismiss a complaint for failing to state a claim upon which relief can be 27 granted under Rule 12(b)(6). “Dismissal under Rule 12(b)(6) is appropriate only where the 1 Mendiondo v. Centinela Hosp. Med. Ctr., 521 F.3d 1097, 1104 (9th Cir. 2008). To survive a Rule 2 12(b)(6) motion, a plaintiff need only plead “enough facts to state a claim to relief that is plausible 3 on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). A claim is facially plausible 4 when a plaintiff pleads “factual content that allows the court to draw the reasonable inference that 5 the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). 6 Rule 9(b) imposes a heightened pleading standard where fraud is an essential element of a 7 claim. See Fed. R. Civ. P. 9(b) (“In alleging fraud or mistake, a party must state with particularity 8 the circumstances constituting fraud or mistake.”); see also Vess v. Ciba–Geigy Corp. USA, 317 9 F.3d 1097, 1107 (9th Cir. 2003). A plaintiff must identify “the who, what, when, where, and how” 10 of the alleged conduct, so as to provide defendants with sufficient information to defend against 11 the charge. Cooper v. Pickett, 137 F.3d 616, 627 (9th Cir. 1997). However, “[m]alice, intent, 12 knowledge, and other conditions of a person's mind may be alleged generally.” Fed. R. Civ. P. 13 Rule 9(b). 14 In reviewing the plausibility of a complaint, courts “accept factual allegations in the 15 complaint as true and construe the pleadings in the light most favorable to the nonmoving party.” 16 Manzarek v. St. Paul Fire & Marine Ins. Co., 519 F.3d 1025, 1031 (9th Cir. 2008). Nevertheless, 17 courts do not “accept as true allegations that are merely conclusory, unwarranted deductions of 18 fact, or unreasonable inferences.” In re Gilead Scis. Secs. Litig., 536 F.3d 1049, 1055 (9th Cir. 19 2008) (quoting Sprewell v. Golden State Warriors, 266 F.3d 979, 988 (9th Cir. 2001)). 20 III. DISCUSSION 21 A. Limitation on Liability 22 As an initial matter, Defendant urges that all of Plaintiff’s claims and requested damages 23 are barred by Facebook’s Terms of Service and Instagram’s Terms of Use. See Dkt. No. 15 at 9– 24 10. Plaintiff, for her part, does not appear to deny that she agreed to the Terms of Service and 25 Terms of Use. See generally Dkt. No. 23. To the contrary, Plaintiff relies on them for some of 26 her causes of action. See id. at 8 (“Here Facebook through its terms created a contractual duty to 27 take action to stop a hacking in progress once they were notified by Plaintiff of the hacking.”) 1 incorporated into the Terms of Service); id. at ¶ 32 (“Facebook’s Terms of Service constitute a 2 binding contract.”); id. at ¶ 51 (alleging that Plaintiff “fulfilled all requirements to receive a blue 3 checkmark” on her Instagram account). The Court finds that it may consider the Terms of Service 4 and Terms of Use as incorporated by reference in the complaint. See United States v. Ritchie, 342 5 F.3d 903, 908 (9th Cir.

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Bluebook (online)
Baldwin Kennedy v. Meta Platforms, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/baldwin-kennedy-v-meta-platforms-inc-cand-2024.