The US Court of Appeals for the Fourth Circuit on Tuesday dismissed a lawsuit seeking to hold Meta, parent company of Facebook, liable for its alleged role in helping radicalize Charleston church shooter Dylann Roof.
The court upheld a lower district court’s decision after a woman, identified only as M.P., filed a complaint asserting that Facebook’s algorithm repeatedly exposed Roof to “extremist” and “racist” content on its platform to boost user engagement for profits. The complaint further argued that violent or racist material could be harmful to users, as repeated exposure could lead people to commit violent or otherwise harmful acts. M.P., present during the shooting in which her father was killed by Roof, concluded that Facebook contributed to Roof’s murder of nine African American worshipers in the June 2015 church shooting in Charleston, South Carolina.
The court disagreed with M.P. on the grounds that Section 230 of the 1996 Communications Decency Act immunized Meta from liability because the Act prevents it from being legally responsible for information published by third parties. Specifically, the Act states that “[n]o provider or user of an interactive computer service shall be treated as the publisher or speaker of any information provided by another information content provider.” The court concluded that Section 230 bars M.P.’s complaint because it seeks to hold Facebook liable as the publisher of the third-party content that Roof consumed prior to engaging in the shooting.
The court further reasoned that M.P. did not meet the legal standard to show that Meta was both the actual and legal causes of the shooting, meaning that her state-based claims were not plausible. In addressing her federal claims, the court determined that she did not timely file the complaint within the required one-year period.
A federal jury sentenced Roof to death in January 2017 after he was convicted of 33 counts of federal hate crimes and for murder.