Zeran v. America Online gives Section 230 a broad reading
Event Reviewed Automatically reviewed for factual accuracy, tone, and neutrality. Review does not check claims against cited sources. Last reviewed 27 October 2026.The Fourth Circuit rules that Section 230 bars defamation claims against AOL over anonymous third-party posts, including claims that AOL was liable as a distributor after being notified, the first federal appellate interpretation of the statute.
First appellate ruling reads Section 230 as broad immunity for platforms.
Sources
- 01.
Electronic Frontier Foundation. Zeran v. America Online, Inc., 129 F.3d 327 (4th Cir. 1997). (1997). Text of the published opinion, No. 97-1523, argued 2 October 1997, decided 12 November 1997; opinion by Chief Judge Wilkinson. Source for the decision date, for the facts (anonymous AOL bulletin-board posts listing Zeran's phone number), and for the holding that Section 230 immunizes AOL from liability for third-party content, including notice-based distributor liability.
- 02.
Jr., D. L. H. (2009). Zeran v. America Online, Inc. (4th Cir.) (1997). Independent secondary account. Supports that the Fourth Circuit rejected distributor liability for AOL under Section 230 and that later federal courts adopted Zeran's interpretation. Used for significance; the date is taken from the opinion.
- 03.
Supreme Court of the United States. Malwarebytes, Inc. v. Enigma Software Group USA, LLC, No. 19-1284 (U.S. Oct. 13, 2020) (statement of Thomas, J., respecting the denial of certiorari). (2020). Source for Zeran being 'the first appellate court to consider the statute' and for its holding that § 230 eliminates distributor liability, although, in Justice Thomas's reading, the text of § 230(c)(1) grants immunity only from publisher or speaker liability.
Page history
Reviewed Oct 27, 2026Recent changes
- Reviewed: 1 finding, all fixed AI review
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