Heeger v. Facebook, Inc.

CourtDistrict Court, N.D. California
DecidedDecember 27, 2019
Docket3:18-cv-06399
StatusUnknown

This text of Heeger v. Facebook, Inc. (Heeger 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
Heeger v. Facebook, Inc., (N.D. Cal. 2019).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 BRETT HEEGER, Case No. 18-cv-06399-JD

8 Plaintiff, ORDER RE MOTION TO DISMISS v. 9 Re: Dkt. No. 26 10 FACEBOOK, INC., Defendant. 11

12 13 This is a privacy class action lawsuit brought by plaintiff Brett Heeger against defendant 14 Facebook, Inc., on behalf of a putative class of Facebook users who turned off Facebook’s 15 “Location History” feature. Heeger alleges that Facebook continued to “track, log, and store” 16 their private location information “regardless of users’ choices” to deactivate that feature. Dkt. 17 No. 1 ¶¶ 1, 43. Facebook has moved to dismiss plaintiff’s complaint under Federal Rules of Civil 18 Procedure 12(b)(1) and 12(b)(6). Dkt. No. 26. The motion is granted and denied in part, with 19 leave to amend. 20 DISCUSSION 21 Facebook’s unopposed request for judicial notice, Dkt. Nos. 27, 32, is granted, and 22 plaintiff’s fifth claim under California’s Consumer Legal Remedies Act, Cal. Civ. Code § 1750 et 23 seq., is dismissed because plaintiff has abandoned that claim to “streamline the case.” Dkt. No. 33 24 at 15 n.12. That leaves four claims: (1) violation of the California Invasion of Privacy Act 25 (“CIPA”), Cal. Pen. Code § 630 et seq.; (2) violation of California’s constitutional right of 26 privacy; (3) intrusion upon seclusion; and (4) violation of the Stored Communications Act 27 (“SCA”), 18 U.S.C. § 2701 et seq. Dkt. No. 1 ¶¶ 52-86. 1 I. ARTICLE III STANDING 2 Facebook says that Heeger lacks Article III standing for all of the claims because he has 3 not alleged a concrete and specific injury in fact. Dkt. No. 26 at 6-9. Heeger originally filed this 4 lawsuit in federal court, and so he bears the burden of establishing Article III jurisdiction. Patel v. 5 Facebook, Inc., 932 F.3d 1264, 1270 (9th Cir. 2019). “[G]eneral factual allegations of injury 6 resulting from the defendant’s conduct may suffice, and we presume that general allegations 7 embrace those specific facts that are necessary to support the claim.” Id. (quotations omitted). 8 The question is whether the intangible harm to privacy that Heeger alleges under federal 9 and state statutes is a concrete injury in fact for Article III purposes. Patel v. Facebook Inc., 290 10 F. Supp. 3d 948, 952 (N.D. Cal. 2018). To determine whether the violation of a statute creates a 11 concrete injury, the Court considers “(1) whether the statutory provisions at issue were established 12 to protect [the plaintiff’s] concrete interests (as opposed to purely procedural rights), and if so, 13 (2) whether the specific procedural violations alleged in this case actually harm, or present a 14 material risk of harm to, such interests.” Patel, 932 F.3d at 1270-71 (quoting Robins v. Spokeo, 15 Inc., 867 F.3d 1108, 1103 (9th Cir. 2017)). History and legislative judgments “play important 16 roles” in the analysis. Patel, 290 F. Supp. 3d at 952. “History is instructive because an intangible 17 harm is likely to be concrete for standing purposes when it bears ‘a close relationship to a harm 18 that has traditionally been regarded as providing a basis for a lawsuit.’” Id. The legislative 19 judgments of Congress and state legislatures are also “‘instructive and important’ to our standing 20 inquiry.” Patel, 932 F.3d at 1273. 21 The complaint alleges that “Facebook systematically and covertly tracks, collects, and 22 stores users’ private location information even after users have affirmatively opted not to share 23 their location history,” Dkt. No. 1 ¶ 9, and that Facebook uses this information “to provide third 24 party companies with targeted advertising” for its own corporate profits. Id. ¶ 34. That is the 25 factual platform for the intrusion upon seclusion claim, and the violations of the California 26 Constitution, CIPA and SCA. 27 These allegations amply establish a concrete injury under Article III. To start with the 1 solitude, seclusion, and private affairs by continuing to track, build and store detailed location 2 histories without their knowledge and consent,” Dkt. No. 1 ¶ 71, and that Facebook exploited that 3 information for its own financial gain. Heeger also alleges a “reasonable expectation[] of privacy 4 in [his] mobile device[] and online behavior generally, including [his] physical locations.” Id. 5 ¶ 69. Such “[p]rivacy rights have long been regarded ‘as providing a basis for a lawsuit in English 6 or American courts.’” Patel, 932 F.3d at 1271 (quoting Spokeo, Inc. v. Robins, 136 S. Ct. 1540, 7 1549 (2016)). “The Supreme Court has likewise recognized the common law roots of the right to 8 privacy,” and “[b]oth the common law and the literal understandings of privacy encompass the 9 individual’s control of information concerning his or her person.” Id. at 1272-73. Consequently, 10 Heeger has adequately alleged an actual and concrete invasion of his privacy rights that is 11 actionable in federal court under Article III. 12 So too for Heeger’s privacy claim under the California Constitution. The California 13 Supreme Court has stated that the “principal focus” for Article I, section 1 is “readily discernible,” 14 and the ballot argument for its passage warned “of unnecessary information gathering, use, and 15 dissemination by public and private entities.” Hill v. Nat’l Collegiate Athletic Ass’n, 7 Cal. 4th 1, 16 21 (1994). “Informational privacy is the core value furthered by the Privacy Initiative,” and the 17 “California constitutional right of privacy ‘prevents government and business interests from 18 (1) collecting and stockpiling unnecessary information about us and from (2) misusing 19 information gathered for one purpose in order to serve other purposes or to embarrass us.’” Id. at 20 35. Heeger has alleged facts sufficient to state a concrete harm in light of these factors. 21 The injuries for the CIPA and SCA claims are also actual and concrete. “In enacting 22 [CIPA], the Legislature declared in broad terms its intent ‘to protect the right of privacy of the 23 people of this state’ from what it perceived as ‘a serious threat to the free exercise of personal 24 liberties [that] cannot be tolerated in a free and civilized society.’ (Pen. Code, § 630.) This 25 philosophy appears to lie at the heart of virtually all the decisions construing the Privacy Act.” 26 Ribas v. Clark, 38 Cal. 3d 355, 359 (1985). And for the Stored Communications Act, our circuit 27 has held that “[b]ecause the plaintiffs allege that Facebook and Zynga are violating statutes that 1 grant persons in the plaintiffs’ position the right to judicial relief, we conclude they have standing 2 to bring this claim.” In re Zynga Privacy Litigation, 750 F.3d 1098, 1105 n.5 (9th Cir. 2014). 3 Consequently, there is no doubt that Heeger has the right to bring this case in federal court. 4 Facebook makes a last effort to avert this conclusion by saying that the SCA and CIPA “do[] not 5 apply” to plaintiff’s allegations. Dkt. No. 26 at 8. The point is not well taken. That is in effect a 6 merits argument, and the jurisdictional and merits inquiries are independent. Patel, 290 F. Supp. 7 3d at 952, 956 (“dispositive disputes on the merits should be decided on summary judgment or at 8 trial, and not in the Rule 12(b)(1) jurisdictional context”) (citing Safe Air for Everyone v. Meyer, 9

Related

Ribas v. Clark
696 P.2d 637 (California Supreme Court, 1985)
United States v. Reed
575 F.3d 900 (Ninth Circuit, 2009)
Hill v. National Collegiate Athletic Assn.
865 P.2d 633 (California Supreme Court, 1994)
Shulman v. Group W Productions, Inc.
955 P.2d 469 (California Supreme Court, 1998)
Nancy Graf v. Zynga Game Network, Inc.
750 F.3d 1098 (Ninth Circuit, 2014)
Spokeo, Inc. v. Robins
578 U.S. 330 (Supreme Court, 2016)
Thomas Robins v. Spokeo, Inc.
867 F.3d 1108 (Ninth Circuit, 2017)
Nimesh Patel v. Facebook, Inc.
932 F.3d 1264 (Ninth Circuit, 2019)
People v. Friend
211 P.3d 520 (California Supreme Court, 2009)
Del Prete v. Thompson
10 F. Supp. 3d 907 (N.D. Illinois, 2014)
McDonald v. Aps
385 F. Supp. 3d 1022 (N.D. California, 2019)
Safe Air for Everyone v. Meyer
373 F.3d 1035 (Ninth Circuit, 2004)
United States v. Yarbrough
290 F. Supp. 4 (N.D. Mississippi, 1968)

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Heeger v. Facebook, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/heeger-v-facebook-inc-cand-2019.