California Appeals Court Confirms That School Districts Can’t Sue Over Social Media Addiction

[I have so many topically related cases in my blogging queue, but I’ve accelerated coverage of this one because of its potential significance.]

An entire financial and regulatory ecosystem has developed around the narrative that social media services illegally addict their users. This belief has become a dominant orthodoxy in most circles. But the thing is, much of this narrative is predicated on assumptions about the law that may not survive appellate review. If the appeals courts undermine some or all of the narrative, an entire ecosystem and an unquestioned orthodoxy could crumble.

In this case, the state trial court rejected several claims from school districts. The state appeals court affirms those rulings. The latest ruling doesn’t flip the lower court ruling, so it doesn’t itself change the litigation or regulatory ecosystem. However, the state appellate ruling does expressly conflict with some conclusions in the federal court case, which has already produced one bellwether settlement favoring a school district, with more bellwether trials on deck. One obvious possibility from this ruling is that the federal school district bellwether trials will fail on appeal, even if the juries side with the school districts before then. In other words, this ruling highlights a sliver of the unstable ground of the social media addiction litigation, just awaiting the inevitable appellate court review.

Negligence

The appellate court provided an overview of the negligence claims:

Plaintiffs allege they suffered three general kinds of harm: (1) “incur[ring] significant financial costs” to address the youth mental health crisis allegedly created by Defendants’ platforms; (2) “frustrat[ion] [of their] pedagogical mission” in diverting staff time and resources from education to counter the disruptive effects of the crisis; and (3) property damage inflicted by students. In part V., we conclude Plaintiffs’ allegations their missions were frustrated do not state a cognizable negligence claim, and in part VI., we conclude Defendants have immunity from liability arising from Plaintiffs’ alleged property damage.

That leaves Plaintiffs with only alleged financial harms—which we conclude in parts II. through IV., post, are not recoverable in negligence in these circumstances under California, Rhode Island, or Florida law. Thus, Plaintiffs have not adequately pled any of the Defendants owed them a duty of care under the laws of their respective states. The trial court properly sustained Defendants’ demurrer to the negligence causes of action.

In a footnote, the court adds: “Our conclusion likewise forecloses Plaintiffs’ argument Defendants owed a duty to warn them of harms posed by Defendants’ platforms. Defendants have no duty to warn of a purported peril they have no duty to prevent.”

The opinion explains why the school districts lose in more detail.

Economic Loss Rule–California

the universe of entities who may have suffered (or will suffer) some sort of financial loss because of the platforms is virtually unlimited…there is no viable geographic (spatial) or temporal limitation on who could seek remedies for their economic losses….

Even assuming San Diego is correct that Defendants’ knowledge of the effects of their platforms on schools shows the harm was foreseeable, this branch of the economic loss rule requires “more than mere foreseeability” to impose liability for purely economic loss.

San Diego pointed to the federal social media addiction litigation, which let the school districts proceed. The court distinguishes that ruling with some strong critical remarks:

that court focused largely on proximate cause and derivative injury arguments that are not at issue here. Its analysis of the economic loss rule was truncated, no doubt in part due to the court’s observation that the parties’ briefing on the topic was brief and provided “little more than case citations.” The court concluded neither of the two “ ‘recurring … circumstances’ ” in which the rule applied “is argued or appears to apply.” We do not find this analysis persuasive

This is what I’m talking about. The federal district court decision emboldened hundreds/thousands of school district plaintiffs to bring negligence claims based on analysis that a state appeals court says is not persuasive. I am sure the defendants will be highlighting this ruling when the federal case goes up on appeal.

Economic Loss Rule–Rhode Island

The question remains whether Rhode Island permits recovery for economic losses under a negligence theory in any other context. West Warwick points to no case outside of the contractual context in which a plaintiff was permitted to sue for purely economic injuries.

Economic Loss Rule–Florida

there was no “appreciable zone of risk” within which Defendants were obligated to protect third parties like Brevard from economic harms, and Brevard has no recognized special interest comparable to the unique commercial fishing exception….

with the exception of Curd, Brevard cites no Florida cases recognizing any purely economic harms falling within a foreseeable zone of risk for purposes of a negligence cause of action. Instead, Brevard relies upon cases exclusively discussing physical harms within that zone.

Property Damage and the Challenge Videos

The economic loss rule doesn’t bar the school districts’ property damage-based negligence claims, but those fail on other grounds.

Plaintiffs do not allege Defendants directly damaged their property; instead, they allege Defendants’ platforms influenced students to vandalize school property because the platforms showed them so-called “challenge videos,” created by third parties, that encouraged vandalizing school property

The lower court dismissed this claim on Section 230 grounds. The appeals court agrees.

[Plaintiffs] concede Defendants are providers of interactive computer services within the meaning of section 230. Plaintiffs do not appear to dispute the challenge videos are information provided by third parties….

Plaintiffs’ causes of action premised on property damage inflicted by students who watched challenge videos arise from Defendants’ decision to publish those videos. As explained in Plaintiffs’ opening briefs, those claims crucially turn on the content of the third party challenge videos…The claims are not content agnostic; they do not remain the same regardless of the types of videos the students watched.

The school districts tried a “but the algorithms” argument based on Anderson v. TikTok. The panel repeats itself: “Plaintiffs’ negligence causes of action, to the extent they are premised on property damage inflicted as a result of challenge videos, turn on the content of those videos.” We’ll count this as another rejection of Anderson v. TikTok in California courts.

This ruling is a reminder that Section 230 plays a role in the social media addiction cases. Obviously many of the claims pled around Section 230 well enough to reach the jury, but some claims–like the school districts’ challenge video claims in state court–never got that far because of Section 230. I think Section 230 should play an even greater role in screening out claims that the state and federal trial court judges did. That will continue to be tested on appeal.

Public Nuisance

Washington

we reject Vancouver’s argument that conduct violating “the right to education” of a community amounts to a public nuisance….

Vancouver failed to allege a public nuisance that “affects equally” the health of either of those “entire communit[ies].”

Nothing in Vancouver’s complaint suggests the health of the entire community of either “(1) [Vancouver’s] student users of Defendants’ platforms [or] (2) all of [Vancouver’s] students” was “affect[ed] equally” by the platforms. Rather, Vancouver alleged: (1) some young users of the platforms use them frequently or even compulsively; (2) some of those frequent or compulsive young users experience mental health problems as a result; (3) many of Vancouver’s students use the platforms, including some who use them compulsively; and (4) Vancouver’s counselors “have seen an increased number of students … struggling with anxiety and other social issues tied to social media.” But none of that suggests the mental health of the entire community of Vancouver’s student users was “affect[ed] equally” by the platforms, let alone the mental health of Vancouver’s entire student body (i.e., users and nonusers alike)….

there are no similar allegations the mental health of the entire community of Vancouver’s student users has been affected by Defendants’ platforms. Instead, a generous reading of the complaint alleges some users were so affected. Without minimizing the harms to those students, that is not enough to state a claim for public nuisance under Washington law.

Nor did Vancouver allege Defendants’ platforms affected the health of its entire student body. That nonuser students were “impact[ed]” by students with mental health issues—which the complaint suggests was because school services for user students came “at the expense of the educational goals and experience for the larger student body”—does not mean the health of nonuser students was affected by the platforms, within the meaning of Washington public nuisance law.

The court reaches the simple conclusion that social media users have heterogeneous reactions to social media (indeed, some users derive substantial benefits from social media). This is so obvious, yet the entire regulatory and financial ecosystem has been predicated on the false narrative that social media is always bad for everyone. When appellate courts probe that assumption, cases will fall apart.

Florida

“Brevard cites no cases finding a nuisance violating a public right to education–from Florida or any other jurisdiction.” The court continues:

Brevard’s complaint does not allege the platforms have indiscriminately harmed the mental health of either. To be sure, the complaint alleges the “platforms can cause addiction, compulsive use, anxiety, depression, eating disorders, … and suicide,” and Brevard’s “counselors have seen an increased number of students … struggling with anxiety … tied to social media.” But while those injuries may be serious for some students, the complaint alleges it is a subset of young users of the platforms who can experience those mental health issues. As with the allegations in Vancouver’s complaint, Brevard’s complaint does not allege that the health of Brevard’s students, let alone of any broader community, was affected indiscriminately or generally by the platforms….

In re Social Media Adolescent Addiction, at pages *13 through *14, did not cite Florida authority in its discussion, and In re JUUL, at pages 647 through 648 and footnotes 73 and 74, did not discuss Florida’s definition of “considerable number of persons.” We therefore do not find those federal cases helpful.

California

California authorizes public agencies to bring nuisance claims only to abate the nuisance, and here the school district also sought damages. It could only sue for financial damages if it alleged property damage, which it did not properly do. “Any connection to property here is abstract at best. Accepting San Diego’s position would convert virtually any personal injury affecting a property owner into a nuisance.”

Conclusion

This ruling provides a reminder that the school district cases over social media addiction are likely overreaching, perhaps to the breaking point.

In particular, the court’s ruling repeatedly highlights one of the biggest concerns about treating social medias as a public nuisance to school districts: if that’s the case, there is no limit to what other entities could be sued for imposing administrative or financial burdens on the school districts; and there is no limit on what other government agencies might claim that private actors are increasing demand for government services. I honestly can’t believe the public nuisance claims have gone anywhere, yet the federal court greenlighted bellwether trials on that basis (and the social media services already paid millions of dollars to a school district as a result). I continue to believe that the public nuisance claims in the federal case will not survive appeal.

Despite the overall weakness of the public nuisance claim, I can see why the school districts would be frustrated with this ruling. Virtually every judgment call broke against them. Like every aspect of the regulatory and plaintiff endeavors against social media addiction, this ruling will surely be appealed.

Case Citation: Social Media Cases: San Diego Unified School District v. Meta Platforms, Inc., 2026 WL 3347173 (Cal. App. Ct. Nov. 5, 2026). This opinion was authored by Justice Anne Richardson.