Meta Platforms Inc. defeated a lawsuit from a sex trafficking victim who alleged the company’s Instagram social media app “created a breeding ground for human trafficking” by failing to verify the identities of its users.

Judge Rita F. Lin of the US District Court for the Northern District of California dismissed the suit, finding that a tech industry federal immunity law blocks the complaint in its entirety.

Section 230 of the federal Communications Decency Act immunizes Meta against the suit’s allegations that Instagram failed to quickly take action on sex trafficking posts or to properly verify users’ ages and identities, Lin said.

The plaintiff “is seeking to impose liability against Meta based on its publication of the third-party content, which is precisely the type of claim precluded by Section 230,” she said in a March 3 ruling.

Section 230, passed by Congress in 1996, blocks civil lawsuits against internet platforms that stem from actions and content posted by users.

The plaintiff, who goes by Jane Doe in court proceedings, alleged that in 2017 she was contacted on Instagram by a sex trafficker who gained her trust and began to groom her. The trafficker later advertised her for sex on the platform for over a year. The plaintiff first sued in Texas state court before the case was transferred to California.

The trafficker was later convicted in a criminal trial and sentenced to 40 years in prison.

An attorney for the plaintiff didn’t immediately return a request for comment on the court’s decision.

The complaint alleged Meta’s algorithms created “connections” between traffickers with and potential victims. In an effort to bypass Section 230, the Doe complaint asserted defective design theories under product liability law, a strategy that plaintiffs’ attorneys have employed with some success in the past.

But Lin rejected those arguments, finding that claims alleging Instagram was defectively designed by allowing fake accounts that facility sex trafficking still ultimately attempt to hold Meta liable for its editorial decisions, which is prohibited under Section 230.

The judge pointed to the Ninth Circuit precedential Feb. 18 decision in Doe v. Grindr Inc., which said Section 230 blocks a lawsuit from an underage Grindr user who alleged the dating platform connected him with men who sexually abused him.

Bracewell LLP, Boucher LLP, Annie McAdams PC, and Sico Hoelscher Harris LLP represent the plaintiff. Gibson Dunn & Crutcher LLP represents Meta.

The case is Doe (K.B.) v. Backpage.com LLC, N.D. Cal., No. 3:23-cv-02387, 3/3/25.