Snapchat not liable for enabling teacher to groom minor student

A high school science teacher used Snapchat to send sexually explicit content to one of her students, whom she eventually assaulted. Authorities uncovered this abuse after the student overdosed on drugs. The student (as John Doe) sued the teacher, the school district and Snapchat. The lower court threw out the case against Snapchat on the basis of the federal Communications Decency Act at 47 USC § 230. The student sought review with the United States Court of Appeals for the Fifth Circuit. On appeal, the court affirmed.

Relying on Doe v. MySpace, Inc., 528 F.3d 413 (5th Cir. 2008), the court affirmed the lower court’s finding that the student’s claims against Snapchat were based on the teacher’s messages. Accordingly, Snapchat was immune from liability because this provision of federal law – under the doctrine of the MySpace case – provides “immunity … to Web-based service providers for all claims stemming from their publication of information created by third parties.”

Doe v. Snap, Inc., 2023 WL 4174061 (5th Cir. June 26, 2023)

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