Patrick Santoro; Jessica Landis v. Tower Health; Meta Platforms, Inc.
Summary
Patients alleged Tower Health shared identifiable health information through Meta Pixel. The appellate court affirmed the challenged orders without deciding substantive pleading sufficiency.
Litigation Status
Procedural Posture
Appeal from dismissal and denial of a postjudgment request to amend; claims against Meta had been transferred elsewhere.
Reported Holding
The court found standing but affirmed dismissal with prejudice and denial of reconsideration.
What the Court Decided
Denying further amendment was within the district court's discretion; plaintiffs unduly delayed after clear notice of pleading deficiencies.
What the Court Did Not Decide
Whether the second amended complaint stated a claim; plaintiffs did not press that issue on appeal.
Significance
Generally viewed as defense-favorable. Characterizations of significance describe how the matter has generally been discussed in tracked public sources; individual holdings are often narrow, procedural, or fact-specific, and this page does not state or imply broader holdings than the sources support.
What This Page Does and Does Not Say
This page reports what our tracked public sources say about this matter — including, where identified, the procedural posture (for example, a ruling on a motion to dismiss is not a final merits decision). It does not report legal conclusions beyond those sources, does not predict outcomes, and does not constitute legal advice.
Technologies at Issue
Third parties named or identified in tracked sources: Meta Platforms, Inc..
Statutes Invoked
Claims Asserted
- ECPA
- Negligence
- Intrusion upon seclusion
What This Matter May Mean for Website Operators
Federal Wiretap Act (ECPA Title I) is a one-party consent statute with a private right of action. Consent standard and private enforceability are the structural features that most shape where website tracking claims are filed and how they are valued.
For operators using similar technologies, the recurring factual questions in matters like this one are whether advertising pixels transmit page URLs or hashed form data before a consent choice. Our scanner tests these behaviors empirically.
The reported outcome direction at the appeal stage reflects how tracked sources characterize the ruling; such rulings are often narrow, posture-specific, and fact-bound rather than broad statements of law.
Detection of a similar technology on a website is an informational risk indicator, not a legal conclusion, and nothing in this section is legal advice.
Related Intelligence
Sources
About This Page
Publisher: Inspection-Ready Institute, Inc. (DBA Crandall Consulting), an independent website compliance and risk consultancy. We are not a law firm and nothing on this page is legal advice.
How this content is produced: Facts are extracted from publicly available sources — court and government materials, recognized legal press, professional analysis, and industry reports — by our litigation intelligence engine, stored with full source provenance, and rendered from the database. Risk guidelines are computed by a deterministic formula, never by an AI model directly. See the full methodology.
Limitations: Counts labeled "Tracked" reflect matters identified in our source set and are not official court statistics. We report what courts decided and did not decide; we do not predict outcomes.
Corrections: If you believe anything on this page is inaccurate, contact us via the contact page and we will review the underlying sources promptly.
Is Your Website Creating Hidden Tracking Risk?
Scan your site for third-party tracking and potential wiretap exposure. Free, no account required.
Scan My Website