Moderation and §230

Joseph Reagle

Barlow

Weary giants

Natural independence

I declare the global social space we are building to be naturally independent of the tyrannies you seek to impose on us. You have no moral right to rule us nor do you possess any methods of enforcement we have true reason to fear. (Barlow 1996)

Our world is different

You claim there are problems among us that you need to solve … as an excuse to invade our precincts. Many of these problems don’t exist … [others] we will identify them and address them by our means. We are forming our own Social Contract. This governance will arise according to the conditions of our world, not yours. Our world is different. (Barlow 1996)

Guard posts overrun

In China, Germany, France, Russia, Singapore, Italy and the United States, you are trying to ward off the virus of liberty by erecting guard posts at the frontiers of Cyberspace. These may keep out the contagion for a small time, but they will not work in a world that will soon be blanketed in bit bearing media (Barlow 1996)

Mind in Cyberspace

We will create a civilization of the Mind in Cyberspace. May it be more humane and fair than the world your governments have made before. (Barlow 1996)

Internet quotations

Why the Internet is good

Why free speech??

  • human right (UNDHR article 19)
  • essential to popular sovereignty and democracy
  • encourages pluralism—better to exchange letters than munitions
  • pragmatic improvements in the marketplace of ideas

ex. Design a regulation of platforms’ moderation

You are in a group of legislatures. What, if anything, user behavior or content should platforms be responsible for?

US law

47 USC § 230

  1. Protection for “Good Samaritan” blocking and screening of offensive material
    1. No provider or user of an interactive computer service shall be treated as the publisher or speaker of any information provided by another
    2. No provider or user of an interactive computer service shall be held liable on account of:
      1. any action voluntarily taken in good faith to restrict access to or availability of material that the provider or user considers to be [objectional] whether or not such material is constitutionally protected; (Congress 1996)

230’s intention

An unidentified Prodigy user posted several statements … which allegedly defamed a brokerage company by falsely accusing it of committing “criminal and fraudulent acts.” The question in Stratton Oakmont [1995] was whether Prodigy could be held liable for these statements… (Millhiser 2022)

— There probably was a “fire”: Stratton Oakmont was the inspiration for The Wolf of Wall Street

Section 230

Challenges

TheDirty.com

This was a website courting mean and (often) defamatory material, including about Sarah Jones (a H.S. teacher and cheerleader).

Yet, Nik Lamas-Richie was not held liable by an appeals court in Jones v. Dirty World because of §230 (Ziniti 2014)

(Dirty World was deindexed by Google and went offline in 2023.)

FOSTA-SESTA

  1. [§ 230’s] Effect on other laws
    1. No effect on criminal law: … chapter 71 (relating to obscenity) or 110 (relating to sexual exploitation of children) of title 18, or any other Federal criminal statute.
    2. No effect on sex trafficking law: …
      1. any charge in a criminal prosecution brought under State law … if the conduct underlying the charge would constitute a violation [where] promotion or facilitation of prostitution is illegal … (Congress 2018)

FOSTA-SESTA critics had worried…

… unnecessary, imprecise, impaired speech, and endangered sex workers

  • Woodhull Freedom Foundation
  • Center for Democracy and Technology
  • Electronic Frontier Foundation
  • ACLU
  • Engine Advocacy
  • Sex Workers Outreach Project
  • Wikimedia Foundation

Backpage is gone

  • 2018 Apr: FOSTA-SESTA signed into law.
  • 2018 Jul: Backpage owners prosecuted for facilitating prostitution and money laundering under Travel Act (§230 provided no immunity).
  • 2021 Sep: Judge Brnovich declared mistrial for excessive references to “child sex trafficking,” which was not the charge. (There’s evidence that Backpage aggressively moderated child exploitation).
  • 2020: Online sex work increases (e.g., Chaturbate & OnlyFans) (Drolet & O’Neill 2020).
  • 2021 Aug: Payment processors prompt OnlyFans to remove explicit content; reverses itself a few days later.

Regulatory backfire, examples

Debate continues…

Concerns over sex exploitation, harassment, hate, and terrorism are complemented by Republican concerns about anti-conservative bias.

Terrorism

In Twitter v. Taamneh and Gonzalez v. Google families of terrorist victims sued platforms.

Supreme Court ruled allegations didn’t establish sufficient culpability of platforms (Lennett 2023).

Under the narrow ruling, the state laws remain intact, but lower court injunctions also remain in place, meaning both laws continue to be paused. Although the justices voted 9-to-0 to return the cases to the lower courts, they splintered on the reasoning (VanSickle et al. 2024).

Justice Kagan’s concern

Moody v. NetChoice (v. Paxton) (2024)

  • The Texas law prohibits take-downs based on the “viewpoint”; individuals and AG can file lawsuits against platforms
  • The Florida law fines platforms if they permanently ban a candidate for office in the state; platforms must be transparent about moderation rules (McCabe 2024)

The cases remanded to lower courts (for additional 1st Amendment analysis) with an injunction against enforcement.

Anderson v. TikTok (2025)

The court concluded that TikTok’s algorithm, which deliberately amplifies certain videos and challenges to users based on their engagement, was not a neutral conduit for user content but an active participant in shaping the content that users see.

In a classic case of cutting both ways the circuit court relied on 2024 SCOTUS opinion Moody v. NetChoice, LLC, which held that content promotion algorithms are a form of protected speech under the 1st Amendment. (Leijon 2025)

Recent events

  • 2020-May Trump’s EO 13925 (“Preventing Online Censorship”): platforms that edit content beyond §230(c)(2)’s “Good Samaritan” exceptions are “engaged in editorial conduct” and may forfeit safe-harbor
  • 2021-May Biden rescinded EO 13925
  • 2025-Jan Trump’s new EO barring government interference with constitutionally protected speech
  • 2025-May “Take It Down Act”: platforms must remove non-consensual intimate imagery within 48 hours—first §230 carve-out since SESTA/FOSTA (2018)
  • 2025-Dec Senate Sunset Section 230 Act would repeal §230 in two years unless Congress enacts a replacement

Media capitulation

  • 2024-Jul Trump threatened Zuckerberg with “life in prison” if he interfered in the election
  • 2024-Dec ABC/Disney paid $15M to Trump (library) to settle Stephanopoulos defamation suit over use of “rape” versus “sexual abuse”
  • 2025-Jan Meta paid $25M to Trump (library) to settle Trump’s 2021 suit over his post-Jan. 6 account suspension

  • 2025-Jul Paramount/CBS paid $16M to settle Trump’s suit over 60 Minutes editing of a Harris interview; legal experts called it frivolous; two CBS News executives resigned in protest
    • FCC chair Brendan Carr approved Paramount’s $8B Skydance merger three weeks after the settlement

Not a principled free speech stand

  • 2025-Jan FCC chair Brendan Carr (co-author of Project 2025’s FCC chapter) launched formal investigations of ABC, CBS, NBC, NPR, and PBS, threatening license revocation for coverage critical of Trump
  • 2025-Feb FTC chair Andrew Ferguson issued a Request for Public Comment on platform “censorship”; by 2025-Mar was arguing content moderation could be an antitrust violation

Other jurisdictions

China (supposedly) bans

Other jurisdictions?

QICs??

What do you think?

Conclusion

Wrap up

  • What will §230 look like in five years? Why? What about other jurisdictions?

Review

  • What will §230 look like in five years? Why? What about other jurisdictions?