Scott v. Meta Platforms Inc.

Background

Natalie Scott, representing herself, sued Meta Platforms Inc. over alleged harm connected to her Facebook account. The complaint alleged that the account was used for privacy violations, offline tracking and harassment, sexual solicitation, psychological abuse, and unauthorized changes that caused reputational damage. Scott also alleged that Meta locked her out of the account for about one and a half years, failed to respond adequately to her complaints, tracked cellphone use and location outside Facebook, and allowed or caused other harmful activity connected to the account.

Scott’s complaint did not expressly identify causes of action. Based on the complaint and Scott’s opposition to the motion, the court understood her allegations as potentially involving negligence, emotional distress, and invasion of privacy. Scott requested $700,000 or the maximum amount allowed in civil court.

Meta moved to dismiss the entire complaint under Federal Rule of Civil Procedure 12(b)(6), which tests whether a complaint legally states a claim for relief. Meta argued that the complaint failed to meet Rule 8, which requires a short and plain statement showing why the plaintiff is entitled to relief. Meta also argued that its Terms of Service barred Scott’s claims, that the complaint did not state a plausible claim, and that Section 230 of the Communications Decency Act barred the claims.

Judicial Notice

The court granted Meta’s request for judicial notice of its Terms of Service. Judicial notice allows a court to accept certain facts or documents without requiring formal proof. The court found that the Terms of Service were publicly available and their contents were not reasonably disputable.

Request to File a Sur-Reply

After briefing on the motion was complete, Scott filed a letter seeking permission to submit supplemental material and object to evidence or arguments in Meta’s reply. The court treated the letter as a request for permission to file a sur-reply, meaning an additional filing after the reply brief.

The court denied Scott’s request to file a sur-reply. It found that Scott had not identified new evidence or a new legal argument that Meta had presented for the first time in its reply. The court stated that Scott could address her concern about her exhibits in an amended complaint, which would replace the original complaint.

Rule 8 and Rule 12(b)(6) Analysis

The court concluded that Scott’s complaint did not comply with Rule 8. Although the court was required to read a self-represented litigant’s pleadings liberally, Scott’s status did not excuse compliance with the pleading rules.

The court found that the complaint bundled possible causes of action into one group of allegations and did not explain which facts supported which claims. Because the complaint did not clearly identify the claims or connect the alleged conduct to particular legal theories, it did not give Meta fair notice of the claims and the grounds for relief. The court therefore dismissed the complaint under Rule 12(b)(6) for failure to comply with Rule 8.

The court did not decide Meta’s remaining arguments concerning the Terms of Service, plausibility, or Section 230. It stated that it could not evaluate those arguments without knowing which facts were connected to which causes of action.

Disposition and Amendment

The court granted Meta’s motion to dismiss the complaint in its entirety. It also granted Scott leave to amend because it was not clear that the pleading’s deficiencies could not be corrected with additional facts. The court directed Scott to identify the specific laws or rights she believed Meta violated, the specific facts supporting each claim, what each person or entity did, and how she was harmed.

The court stated that Scott’s amended complaint had to include all facts, claims, and defendants she wished to present and could not incorporate the original complaint by reference. It required sections addressing jurisdiction, the parties, facts, and separately stated legal claims. Scott could file the amended complaint by April 2, 2026.

Holding

The court granted Meta’s Rule 12(b)(6) motion and dismissed Scott’s complaint in its entirety for failure to satisfy Rule 8. The court granted Scott leave to amend, granted Meta’s request for judicial notice, and denied Scott’s request to file a sur-reply.