John Angelillo v. Facebook
4 and I.O.P. 10.6 April 3
3rd Cir.2025Background
- John Angelillo, a Pennsylvania state prisoner, filed a pro se complaint against Facebook (Meta Platforms), alleging defamatory statements about him were posted on the Facebook platform.
- Angelillo accused Facebook of negligence for permitting defamatory content "unchecked" and sought $68 million in damages.
- The operative complaint was the second amended complaint; prior amendments were allowed but did not cure the alleged defects.
- Facebook moved to dismiss, arguing the court lacked personal jurisdiction over it and that the claims were barred by Section 230 of the Communications Decency Act (CDA).
- The District Court dismissed the complaint, denying further leave to amend, citing lack of jurisdiction and CDA immunity, and the Third Circuit heard the subsequent appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Personal jurisdiction | Facebook subject to suit | No sufficient contacts with PA | Jurisdiction not established |
| CDA § 230 immunity | Facebook responsible for user content | Immune from liability for third-party posts | CDA bars plaintiff's claims |
| Leave to amend | Should be permitted | Futile due to CDA bar and jurisdiction | Further amendment futile |
| Evidentiary hearing | Requested by Angelillo | - | Denied by the court |
Key Cases Cited
- Klayman v. Zuckerberg, 753 F.3d 1354 (D.C. Cir. 2014) (Facebook as an interactive computer service entitled to CDA immunity)
- Danziger & De Llano, LLP v. Morgan Verkamp LLC, 948 F.3d 124 (3d Cir. 2020) (plaintiff bears burden to establish personal jurisdiction)
- Hepp v. Facebook, 14 F.4th 204 (3d Cir. 2021) (CDA § 230 bars treating websites as publishers of third-party content)