Noah v. AOL Time Warner, Inc.
261 F. Supp. 2d 532 (E.D. Va. 2003), aff'd 2004 U.S. App. LEXIS 5495 (4th Cir. 2004)
District Court held Section 230 covered federal claims, opining that "Nor can it be plausibly argued that § 230 is limited to immunity from state law claims for negligence or defamation. Such a limitation is flatly contradicted by § 230's exclusion of some specific federal claims. Those exclusions would be superfluous were § 230 immunity applicable only to certain state claims. Moreover, the exclusion of federal criminal claims, but not federal civil rights claims, clearly indicates, under the canon of expressio unius est exclusio alterius, that Congress did not intend to place federal civil rights claims outside the scope of § 230 immunity." Noah, 261 F. Supp. 2d at 539.
The Appeals Court affirmed the District Court in a two page non-precedential per curiam opinion.