On June 16, 2021, the Fifth Circuit held that social media providers cannot be held secondarily liable under the Anti-Terrorism Act (“ATA”) for aiding and abetting a foreign terrorist organization based on an individual’s acts within the United States.   Plaintiff Retana, a victim of the July 2016 shooting committed by Micah Johnson (“Johnson”) in Dallas, Texas, along with his husband (together “Plaintiffs”) sued several social media companies (“Defendants”) alleging that Defendants were secondarily liable for Retana’s injuries under the ATA because “they provided material support to Hamas, a foreign terrorist organization that used Internet services and social media platforms to radicalize Johnson to carry out the Dallas shooting.” Specifically, Plaintiffs alleged that Defendants were secondarily liable under the ATA because Johnson was radicalized by Hamas’ posts and posts of other hate groups, such as the African American Defense League, since Johnson “liked” their pages. Five days prior to the shooting, Johnson also posted a “rant” against white people on social media, and, four days later the African American Defense League posted that it was “time to act.”