Hart v. Facebook, Inc.

CourtDistrict Court, N.D. California
DecidedMay 5, 2022
Docket3:22-cv-00737
StatusUnknown

This text of Hart v. Facebook, Inc. (Hart v. Facebook, 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
Hart v. Facebook, Inc., (N.D. Cal. 2022).

Opinion

1 2 3 4 5 IN THE UNITED STATES DISTRICT COURT 6 FOR THE NORTHERN DISTRICT OF CALIFORNIA 7 8 JUSTIN HART, Case No. 22-cv-00737-CRB

9 Plaintiff,

ORDER GRANTING MOTIONS TO 10 v. DISMISS

11 FACEBOOK INC., et al., 12 Defendants.

13 Plaintiff Justin Hart, a California resident, is suing Defendants Facebook Inc., 14 Twitter Inc., President Joseph Biden, Surgeon General Vivek Murthy, the Department of 15 Health and Human Services (HHS), and the Office of Management and Budget (OMB). 16 See Compl. (dkt. 1). Hart alleges that, between late 2020 and mid-2021, Facebook and 17 Twitter flagged his posts as misinformation about COVID-19 and suspended or locked his 18 accounts. Hart contends that these acts violated the First Amendment of the United States 19 Constitution because President Biden and Surgeon General Murthy (collectively, Federal 20 Defendants) allegedly acted jointly with Facebook and Twitter. Hart also argues that 21 Facebook and Twitter violated the Free Speech Clause of the California Constitution as 22 well as California contract and tort law.1 Facebook, Twitter, and the Federal Defendants 23 move to dismiss. Facebook and Twitter also move to strike under California’s anti-SLAPP 24 statute. Finding oral argument unnecessary, the Court GRANTS the motions to dismiss 25 without leave to amend. The Court declines to reach the motions to strike. 26 27 1 Hart also raises a claim against HHS and OMB, but this order does not discuss it, as they did not move to dismiss. Hart alleges that they violated the Freedom of Information Act (FOIA) by I. BACKGROUND 1 A. Parties 2 Hart is a resident of San Diego County, California. Compl. ¶ Intro 12.2 He is “the 3 Chief Data Analyst and founder of RationalGround.com, which helps companies, public 4 policy officials, and parents gauge the impact of COVID-19 across the country.” Id. Hart 5 has used Facebook since 2007 as a networking tool for his consulting business and for his 6 website. Id. ¶¶ 30–34. That same year, Hart joined Twitter, which he uses for the same 7 reasons and “as a feeder for his other social media accounts.” Id. ¶¶ 47, 48. 8 Facebook Inc. is a corporation with its principal place of business in California that 9 hosts “one of the most popular social media sites,” boasting “more than 2.8 billion monthly 10 users worldwide.” Id. ¶ 21. 11 Twitter Inc. is a corporation with its principal place of business in California that 12 runs a popular social media site used by “more than one in five adult Americans.” Id. ¶ 41. 13 Vivek Murthy is Surgeon General of the United States and “directs the office of the 14 Surgeon General.” Id. ¶ Intro 15. 15 Joseph R. Biden, Jr. is President of the United States and directs the federal 16 executive branch, including White House staff. Id. ¶ Intro 16. 17 B. Facts 18 1. Terms of Use 19 Because Hart “refers extensively” to Facebook’s Terms of Service and Community 20 Standards and Twitter’s Terms of Service, they are incorporated by reference into the 21 complaint. Khoja v. Orexigen Therapeutics, Inc., 899 F.3d 988, 1002 (9th Cir. 2018); see 22 Compl. ¶¶ 25–26 & nn. 17–19 (Facebook’s Terms of Service and Community Standards); 23 id. ¶¶ 44–46 & nn. 30-31 (Twitter’s Terms of Service); see also Twitter RJN (dkt. 71); 24 Facebook Mot. (dkt. 73) at 3 n.2. 25 26

27 2 The complaint numbers paragraphs from 1 to 26 (for sections on Introduction, Parties, and 1 At the relevant times, Facebook’s Terms of Service forbade users from sharing 2 “anything . . . [t]hat is unlawful, misleading, discriminatory, or fraudulent.” See 3 https://web.archive.org/web/20210718231018/https://www.facebook.com/legal/terms/plain 4 _text_terms (Facebook Terms of Service). The Terms of Service also forbade users from 5 sharing anything that violated its “Community Standards.” See id. One category of 6 speech that could violate Facebook’s Community Standards was “Integrity and 7 Authenticity,” Compl. ¶ 27, of which a subcategory was “False News.” See 8 https://web.archive.org/web/20210713153441/https://www.facebook.com/communitystand 9 ards/integrity_authenticity (Facebook Community Standards). The Terms of Service also 10 stated that Facebook “can remove or restrict access to content that is in violation of these 11 provisions.” See Facebook Terms of Service. 12 Twitter similarly conditions the use of its platform on compliance with its Terms of 13 Service and various rules and policies, which are posted on Twitter’s website. See Compl. 14 ¶¶ 44-46. By accepting Twitter’s User Agreement, a Twitter user agrees to be bound by 15 the current version of the Terms of Service. See Patchen Decl. Ex. 1 (dkt. 70-2) § 6 16 (Twitter Terms of Service). In its Terms of Service, Twitter “reserve[s] the right to 17 remove Content that violates the User Agreement” and directs people to its website for 18 information “regarding specific policies and the process for reporting or appealing 19 violations.” Id. § 3. One of Twitter’s policies prohibits using “Twitter’s services to share 20 false or misleading information about COVID-19 which may lead to harm.” Patchen Decl. 21 Ex. 3 (dkt. 70-4) (Twitter Covid-19 Misleading Information Policy). The policy further 22 states that Twitter “will label or remove false or misleading information” about personal 23 protective equipment “such as claims about the efficacy and safety of face masks to reduce 24 viral spread” and that penalties may include account locks. Id. 25 2. Allegations as to Facebook 26 Beginning in September 2020, Hart’s Facebook posts triggered warnings from 27 Facebook that they “violated its Community Standard[s].” Id. ¶¶ 35–37. First, on or 1 which Hart described a video as depicting “cops defending” a statue of Christopher 2 Columbus in Chicago from “hundreds of ‘peaceful’ protestors throw[ing] bottles, cans, 3 canes, and rocks” as part of a “BLM/SJW rally.” Id. ¶ 35. Hart alleges that Facebook’s 4 warning claimed that “[f]alse information about COVID-19 [was] found in your post.” Id. 5 On September 25, Facebook banned Hart for 30 days from advertising on Facebook and 6 from “live” communication with his followers after he posted “‘Spotify seems like a great 7 place to work!’ – Joseph Goebbels.” Id. ¶ 36. 8 On April 23, 2021, Facebook restricted Hart from posting or commenting for 24 9 hours because it stated that three of Hart’s posts from earlier in April violated its 10 Community Standards:

11 If you ever want to know where your BLM donation is going – the co-founder ‘trained Marxist’ Patrisee Cullars – just bought 12 this amazing home in LA. (Id. ¶ 37(a))

13 This is the truth: Covid is almost gone in America. Hospitals are literally empty. Every willing senior has already been 14 vaccinated. In a few weeks every willing adult can be… (Id. ¶ 37(c)) 15 (Hart alleges that the third post “was removed from Facebook” but does not allege 16 anything about its content. Id. ¶ 37(b).) 17 Finally, on July 13, 2021, Hart posted an infographic on his personal Facebook page 18 entitled “Masking Children is Impractical and Not Backed by Research or Real World 19 Data.” Id. ¶ 1. The post argued, among other things, that masking “can often cause 20 headaches and fatigue,” that “[s]ome masks contain toxic chemicals,” “[d]eaf & disabled 21 children struggle to learn with masks,” and masking could “cause a wide variety of . . . 22 health issues.” Id. ¶ 2. Hart alleges that the graphic is “science-based” and contained 23 footnotes to scientific evidence supporting the claims. Id. ¶ 3. Facebook flagged the post 24 with the following notice: 25 You can’t post or comment for 3 days. 26 This is because you previously posted something that didn’t 27 follow our Community Standards. could cause physical harm, so only you can see it. 1 Learn more about updates to our standards. 2 Id. ¶ 4.

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Hart v. Facebook, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/hart-v-facebook-inc-cand-2022.