Cameron Atkinson v. Meta Platforms, Inc.

CourtCourt of Appeals for the Ninth Circuit
DecidedNovember 22, 2021
Docket20-17489
StatusUnpublished

This text of Cameron Atkinson v. Meta Platforms, Inc. (Cameron Atkinson v. Meta Platforms, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Ninth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cameron Atkinson v. Meta Platforms, Inc., (9th Cir. 2021).

Opinion

FILED NOT FOR PUBLICATION NOV 22 2021 UNITED STATES COURT OF APPEALS MOLLY C. DWYER, CLERK U.S. COURT OF APPEALS

FOR THE NINTH CIRCUIT

CAMERON LEE ATKINSON, No. 20-17489

Plaintiff-Appellant, D.C. No. 3:20-cv-05546-RS

v. MEMORANDUM* META PLATFORMS, INC.; MARK ZUCKERBERG,

Defendants-Appellees.

Appeal from the United States District Court for the Northern District of California Richard Seeborg, Chief District Judge, Presiding

Submitted November 18, 2021** San Francisco, California

Before: THOMAS, Chief Judge, McKEOWN, Circuit Judge, and MOLLOY,*** District Judge.

* This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3. ** The panel unanimously concludes this case is suitable for decision without oral argument. See Fed. R. App. P. 34(a)(2). *** The Honorable Donald W. Molloy, United States District Judge for the District of Montana, sitting by designation. Atkinson appeals the dismissal of his claims without leave to amend. We

have jurisdiction under 28 U.S.C. § 1291. We affirm.

We review de novo dismissals for failure to state a claim under Federal Rule

of Civil Procedure 12(b)(6). Wilson v. Lynch, 835 F.3d 1083, 1090 (9th Cir. 2016),

sub nom. Wilson v. Sessions, 137 S. Ct. 1396 (2017). We review constitutional

issues de novo, Berry v. Dep’t of Soc. Servs., 447 F.3d 642, 648 (9th Cir. 2006)

(First Amendment), and consider factual findings more rigorously when First

Amendment challenges are involved. Cf. Lair v. Bullock, 798 F.3d 736, 748 n.8

(9th Cir. 2015) (“[O]ur review in First Amendment cases is more rigorous than

other cases, [but] we still give some deference to the district court’s factual

findings.”). We review questions of statutory interpretation informing dismissal de

novo, Lemmon v. Snap, Inc., 995 F.3d 1085, 1090 (9th Cir. 2021), and denials of

leave to amend for abuse of discretion, Wilson, 835 F.3d at 1090.

I

The district court properly dismissed Atkinson’s First Amendment claim

because he did not allege sufficient facts to infer that Meta Platforms is a

2 government actor.1 Unless certain exceptions apply, the First Amendment only

restricts government action. Manhattan Cmty. Access Corp. v. Halleck, 139 S. Ct.

1921, 1928 (2019) (enumerating exceptions). Dismissal is proper when a

complaint lacks “a cognizable legal theory” or “sufficient well-pleaded,

nonconclusory factual allegations” to state a plausible claim for relief. Beckington

v. Am. Airlines, Inc., 926 F.3d 595, 604 (9th Cir. 2019) (internal quotation marks

and citation omitted).

Atkinson does not allege plausibly that the federal government “compel[led]

[Meta Platforms] to take a particular action,” Halleck, 139 S. Ct. at 1928, or

“exercised coercive power,” Blum v. Yaretsky, 457 U.S. 991, 1004 (1982).

Allegations of federal coercion do not support the deprivation under color of state

law that Atkinson pleaded. See 42 U.S.C. § 1983; Heineke v. Santa Clara Univ.,

965 F.3d 1009, 1013 n.3 (9th Cir. 2020) (finding that private actors are only

subject to § 1983 liability under a state action theory). Even if such facts could

support his claim, Atkinson does not allege federal coercion sufficiently. Instead,

1 Atkinson does not appeal the district court’s dismissal of his argument that Meta Platforms’ performance of a traditional, exclusive public function made it a government actor, see Manhattan Cmty. Access Corp. v. Halleck, 139 S. Ct. 1921, 1928 (2019), so we do not address it. 3 his allegations cast Meta Platforms’ decision to adopt community standards as a

self-interested business decision.

Atkinson also does not plead sufficient facts to infer that Meta Platforms

acted jointly with state governments. Halleck, 139 S. Ct. at 1928. We need not

accept as true factual allegations that Atkinson’s submitted exhibit contradicts.

Gonzalez v. Planned Parenthood of L.A., 759 F.3d 1112, 1115 (9th Cir. 2014). To

the extent that Atkinson’s allegations are not contradicted, they still do not reflect

joint action. Absent more, the fact that state officials responded to Meta Platforms’

unsolicited inquiries does not plausibly allege such a degree of “interdependence . .

. that [the state] must be recognized as a joint participant” in Meta Platforms’

editorial decisions. Tsao v. Desert Place, Inc., 698 F.3d 1128, 1140 (9th Cir.

2012) (citation omitted). Atkinson does not offer other facts that would make a

joint action claim plausible, such as an agreement between state governments and

Meta Platforms; state participation in Meta Platforms’ corporate governance;

financial ties between state governments and Meta Platforms; or Meta Platforms’

regulation of state activities. Cf. Brentwood v. Tenn. Secondary Sch. Athletic

Ass’n, 531 U.S. 288, 298–302 (2001) (explaining state action existed under such

circumstances). We cannot infer that state officials “dominate[d]” Meta Platforms’

4 decision making from Atkinson’s allegations. Villegas v. Gilroy Garlic Festival

Ass’n, 541 F.3d 950, 955 (9th Cir. 2008).

Finally, Section 230 of the Communications Decency Act does not

independently transform Meta Platforms into a government actor for First

Amendment purposes. 47 U.S.C. § 230. Here, too, allegations that Meta Platforms

was a federal actor cannot support Atkinson’s § 1983 claim. Heineke, 965 F.3d at

1013 n.3.

II

The district court correctly dismissed Atkinson’s claim pleaded under

Section 230 because the provision does not establish a private right of action.

Private rights of action to enforce federal law “must be created by Congress,” and

without a statutory manifestation of congressional intent, “a [private] cause of

action does not exist and courts may not create one[.]” Alexander v. Sandoval, 532

U.S. 275, 286–87 (2001).

Section 230 does not explicitly create a private right to sue, see 47 U.S.C.

§ 230, nor do its “language, structure, context, [or] legislative history” implicitly

reflect any congressional intent to establish one. Lil’ Man in the Boat, Inc. v. City

and County of San Francisco, 5 F.4th 952, 958 (9th Cir. 2021).

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Related

Blum v. Yaretsky
457 U.S. 991 (Supreme Court, 1982)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Laurie Tsao v. Desert Palace, Inc.
698 F.3d 1128 (Ninth Circuit, 2012)
Barnes v. Yahoo!, Inc.
570 F.3d 1096 (Ninth Circuit, 2009)
Villegas v. Gilroy Garlic Festival Ass'n
541 F.3d 950 (Ninth Circuit, 2008)
AlohaCare v. Hawaii, Department of Human Services
572 F.3d 740 (Ninth Circuit, 2009)
Alexander v. Sandoval
532 U.S. 275 (Supreme Court, 2001)
P. Victor Gonzalez v. Planned Parenthood of La
759 F.3d 1112 (Ninth Circuit, 2014)
S. Wilson v. Loretta E. Lynch
835 F.3d 1083 (Ninth Circuit, 2016)
Ufcw Local 1500 Pension Fund v. Marissa Mayer
895 F.3d 695 (Ninth Circuit, 2018)
Bruce Beckington v. American Airlines, Inc.
926 F.3d 595 (Ninth Circuit, 2019)
Manhattan Community Access Corp. v. Halleck
587 U.S. 802 (Supreme Court, 2019)
Parents for Privacy v. William Barr
949 F.3d 1210 (Ninth Circuit, 2020)
John Heineke v. Santa Clara University
965 F.3d 1009 (Ninth Circuit, 2020)
Carly Lemmon v. Snap, Inc.
995 F.3d 1085 (Ninth Circuit, 2021)
Lair v. Bullock
798 F.3d 736 (Ninth Circuit, 2015)

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