Summary
This Vermont Supreme Court opinion addresses an interlocutory appeal concerning whether the state court has specific personal jurisdiction over Meta Platforms, Inc., a nonresident defendant accused of violating the Vermont Consumer Protection Act through its Instagram platform. The court analyzes the minimum contacts and purposeful availment requirements under the Due Process Clause, concluding that Meta’s deliberate exploitation of the Vermont market through targeted advertising and user engagement data satisfies jurisdictional standards. Accordingly, the court affirms the superior court’s denial of Meta’s motion to dismiss for lack of personal jurisdiction.
Topics
Practice areas
Questions Presented
- Whether Vermont courts have specific personal jurisdiction over Meta Platforms, Inc. under the Vermont long‑arm statute and the Due Process Clause.
- Whether the State's consumer‑protection claims arise out of or relate to Meta's contacts with Vermont, satisfying the relatedness prong of specific jurisdiction.
Holdings
- Vermont has specific personal jurisdiction over Meta because Meta purposefully availed itself of the Vermont market by entering contracts with Vermont users, selling advertising to Vermont businesses, and deliberately targeting Vermont teens.
- The claims arise out of Meta's contacts because the alleged unfair and deceptive practices are tied to Meta's business model that targets Vermont users and advertisers.
Key quotations
“A state court may exercise personal jurisdiction over a defendant if the defendant has “certain minimum contacts with [the forum state] such that the maintenance of the suit does not offend traditional notions of fair play and substantial justice.”” (¶ 14)
“Specific jurisdiction is a claim‑specific inquiry. To be subject to specific jurisdiction, the defendant (1) must take some act by which it purposefully avails itself of the privilege of conducting activities within the forum State and (2) the plaintiff’s claims must arise out of or relate to the defendant’s contacts with the forum.” (¶ 15)
Factual background
Meta Platforms operates Instagram, a nationwide social‑media app used by tens of thousands of Vermont teens. Meta contracts with Vermont users, collects personal data, and sells targeted advertising to Vermont businesses. The State alleges Meta's design and business practices are unfair and deceptive under the Vermont Consumer Protection Act.
Procedural history
The Superior Court, Chittenden Unit, Civil Division denied Meta's 12(b)(2) motion, finding sufficient contacts with Vermont to support specific personal jurisdiction. Meta appealed that order under V.R.A.P. 5(b)(1).