District of Columbia v. Facebook, Inc.

CourtDistrict of Columbia Court of Appeals
DecidedJuly 31, 2025
Docket23-CV-0550
StatusPublished

This text of District of Columbia v. Facebook, Inc. (District of Columbia v. Facebook, Inc.) is published on Counsel Stack Legal Research, covering District of Columbia Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
District of Columbia v. Facebook, Inc., (D.C. 2025).

Opinion

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DISTRICT OF COLUMBIA COURT OF APPEALS

No. 23-CV-0550

DISTRICT OF COLUMBIA, APPELLANT,

V.

FACEBOOK, INC., APPELLEE.

Appeal from the Superior Court of the District of Columbia (2018-CA-008715-B)

(Hon. Maurice A. Ross, Motions Judge)

(Argued January 30, 2025 Decided July 31, 2025)

Jeremy R. Girton, Assistant Attorney General, with whom Brian L. Schwalb, Attorney General for the District of Columbia, Caroline S. Van Zile, Solicitor General, Ashwin P. Phatak, Principal Deputy Solicitor General, and Graham E. Phillips, Deputy Solicitor General, were on the briefs, for appellant.

Joshua S. Lipshutz, with whom Karin Portlock, of the bar of the State of New York, pro hac vice, by special leave of court, Helgi C. Walker, and Katherine Moran Meeks were on the brief, for appellee. Before the case was argued, this court granted the motion of Katherine Moran Meeks to withdraw as co-counsel of record.

Before MCLEESE, DEAHL, and SHANKER, Associate Judges.

SHANKER, Associate Judge: The District of Columbia’s Consumer Protection

Procedures Act (CPPA) protects consumers against false, deceptive, or unfair

business practices. For much of the CPPA’s history, claims under the statute had to 2

be based on intentional conduct. Those intentional CPPA claims often involved

intentional misrepresentations akin to common-law fraud. Nearly two decades ago,

we held that certain CPPA claims could be based on unintentional

misrepresentations. But we left one question open: must CPPA claims based on

unintentional misrepresentations be proved by clear and convincing evidence (like

common-law fraud and CPPA claims based on intentional misrepresentations) or by

a preponderance of the evidence? Today we hold that CPPA claims based on

unintentional misrepresentations need only be proved by a preponderance of the

evidence.

The CPPA claims in this case stem from the widely publicized Cambridge

Analytica data leak. In 2018, the Guardian newspaper exposed that the consulting

firm Cambridge Analytica had improperly purchased data that had been gleaned

from tens of millions of individuals with accounts on Facebook, Inc. After the news

broke, Facebook’s stock value plummeted, Facebook account holders deactivated or

deleted their Facebook accounts, and governmental bodies around the globe

launched investigations into Facebook’s conduct. The District of Columbia

launched one such investigation and brought an action against Facebook for

violating the CPPA. 3

In the District’s telling, Facebook violated the CPPA by unintentionally

misleading consumers about which of their data was accessible to third-party

applications through a Facebook user’s friends and about Facebook’s enforcement

capabilities for auditing third-party applications. The District also alleged that

Facebook made a material omission by failing to disclose to users that their data had

been obtained in violation of Facebook’s policies. Facebook moved for summary

judgment on the District’s claims. The trial court granted summary judgment for

Facebook after observing that the District had to prove its CPPA claims by clear and

convincing evidence. In light of our conclusion that CPPA claims based on

unintentional conduct may be proved by a preponderance of the evidence, we reverse

and remand for the trial court to consider whether summary judgment is appropriate

under the correct burden of proof.

Also at issue in this case is the trial court’s exclusion of the District’s sole

expert witness, Dr. Florian Schaub. The trial court held a hearing at which it

expressed criticism of Dr. Schaub’s analytical methods and analysis. The court

subsequently granted Facebook’s motion to exclude the testimony in its entirety,

referring perfunctorily to the reasons stated at the hearing and in Facebook’s motion.

The trial court’s written order makes meaningful appellate review challenging, and,

while the court’s statements at the hearing provide some insight into its views on

aspects of Dr. Schaub’s approach, we are unable on this record to discern the specific 4

concerns the court had under Motorola Inc. v. Murray, 147 A.3d 751 (D.C. 2016)

(en banc), as to some of Dr. Schaub’s three methods of analysis. Accordingly, we

reverse the trial court’s order excluding the testimony in its entirety and remand for

further analysis and explanation.

I. Background

We begin with a background on the CPPA, followed by a brief overview of

Facebook’s privacy policies leading up to the Cambridge Analytica data leak. We

then describe the District’s CPPA claims and the relevant procedural background.

A. Legal Background

The CPPA protects consumers against false, deceptive, or unfair business

practices. Earth Island Inst. v. Coca-Cola Co., 321 A.3d 654, 663 (D.C. 2024). It

is a broad consumer protection statute, meant to “assure that a just mechanism exists

to remedy all improper trade practices.” D.C. Code § 28-3901(b)(1). It “establishes

an enforceable right to truthful information from merchants about consumer goods

and services,” and is to be “construed and applied liberally” to effectuate that

purpose. D.C. Code § 28-3901(c).

Under the CPPA, people and businesses are precluded from

“misrepresent[ing]” any “material fact which has a tendency to mislead.” D.C. Code 5

§ 28-3904(e). That prohibition extends beyond literal falsehoods and includes any

omissions, “innuendo[s],” or “ambiguit[ies]” that have a tendency to mislead

reasonable consumers. Id. § 28-3904(f-l). We consider an alleged violation of the

CPPA “in terms of how the practice would be viewed and understood by a

reasonable consumer.” Saucier v. Countrywide Home Loans, 64 A.3d 428, 442

(D.C. 2013) (quoting Pearson v. Chung, 961 A.2d 1067, 1075 (D.C. 2008)).

“Importantly, we have recognized that whether a trade practice is misleading under

the CPPA generally is a question of fact for the jury and not a question of law for

the court.” Ctr. for Inquiry Inc. v. Walmart, Inc., 283 A.3d 109, 120 (D.C. 2022)

(citation modified).

“With regard to the ‘tendency to mislead,’ a reasonable consumer generally

would not deem an accurate statement to be misleading, and hence, such statement

generally would not be actionable under § 28-3904(e) and (f).” Saucier, 64 A.3d at

442. But we have also recognized that prominent misleading claims are actionable

even when the small print tells the truth. Ctr. for Inquiry, 283 A.3d at 121 (“But, as

other courts have reasoned in applying the reasonable-consumer test, ‘the reasonable

consumer standard does not presume, at least as a matter of law, that reasonable

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