Yesterday, TechFreedom filed an amicus brief urging the Massachusetts Supreme Judicial Court to block a Massachusetts lawsuit that attacks Meta’s social-media design features. The state contends that Meta’s platforms are “addictive.” This emotionally charged claim amounts, at bottom, to an attack on the speech rights of the many ordinary people who speak their minds, and receive information from others, on these platforms. TechFreedom’s brief explains that Massachusetts’s suit is barred by Section 230.
“Section 230 protects technological innovation, whether Massachusetts likes it or not,” said Corbin K. Barthold, Director of Appellate Litigation at TechFreedom. “The law explicitly seeks to ‘promote the continued development of the Internet.’ This is the lens through which to understand Section 230’s protection of websites from liability for exercising the traditional editorial functions of a publisher—preparing, arranging, and distributing third-party content. The features Massachusetts attacks—such as autoplay, infinite scroll, and notifications—are nothing more than digital methods of making editorial choices about how to display user-generated material.”
“For all its talk of ‘product design,’ Massachusetts just wants to play censor,” Barthold continued. “There is no coherent way to separate the act of publishing content from the choices involved in presenting it. Infinite scroll, autoplay, and notifications have no meaning apart from the user-generated content they deliver. Section 230 draws no line between traditional editorial devices, such as headlines or chapter breaks, and their digital counterparts. If Massachusetts had aimed its lawsuit at newspapers, its censorial intent would be obvious.”
“What Massachusetts objects to, in the end, is speech itself,” Barthold concluded. “Minors spend time on social media because, when they’re there, they see speech they’re interested in seeing. Massachusetts is concerned that the speech is too powerful. This problem, however—if it’s a problem—is not for Massachusetts to fix. Under the First Amendment, the strong effects of speech are an inherent part of speech—not a ground for regulation.”
The case is Commonwealth v. Meta, No. SJC-13747 (Mass. S.J.C.). TechFreedom is grateful for the pro bono assistance of Dave Geiger, a partner at Foley Hoag LLP.
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Find this brief and release on our website, and share it on Twitter and Bluesky. We can be reached for comment at media@techfreedom.org. Read our related work, including:
- Tech Policy Podcast: Revising Section 230 Will Silence Marginalized Voices (Aug. 11, 2025)
- Section 230: Legal and Regulatory Battles Reshaping Online Speech, INCOMPAS (Mar. 11, 2025)
- Tech Policy Podcast: Why Section 230 Matters (Dec. 30, 2024)
- Amicus brief urging the Third Circuit to grant full-court review of a deeply incorrect panel decision gutting Section 230 (Oct. 8, 2024)
- The Third Circuit’s Section 230 Decision In Anderson v. TikTok Is Pure Poppycock, Techdirt (Sep. 3, 2024)
- Our letter to the House Energy and Commerce Committee on legislative proposal to sunset Section 230 (May 21, 2024)
- Our letter to the Senate Judiciary Committee for the proposed “No Section 230 Immunity for AI Act” (Dec. 11, 2023)
- Our Supreme Court amicus brief in Moody v. NetChoice (Dec. 7, 2023)
- Opening Arguments #753: Gonzalez v. Google: The Case That (Didn’t) Break the Internet, (Jun. 1, 2023)
- Four Things to Watch in Gonzalez v. Google, FedSoc Blog (Mar. 17, 2023)
- Don’t Repeal the Law That Created the Internet, Ripon Forum (Feb. 23, 2023)
- Tech Policy Podcast: Gonzalez v. Google (Feb. 14, 2023)
- Our Supreme Court amicus brief in Gonzalez v. Google (Jan. 18, 2023)
- Section 230 Heads to the Supreme Court, Reason (Nov. 4, 2022)
- Tech PolicyPodcast: Section 230’s Long Path to SCOTUS (Oct. 31, 2022)
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TechFreedom is a nonprofit, nonpartisan technology policy think tank. We work to chart a path forward for policymakers towards a bright future where technology enhances freedom, and freedom enhances technology.
