Missouri, Arizona, and 14 States Have All Taken Legal Action Against TikTok

Three separate legal actions against TikTok over child safety have emerged recently, from Missouri, Arizona, and a coalition of 14 attorneys general led by New York and California. Missouri’s is an investigation into how TikTok’s algorithm and data practices affect young users. Arizona’s and the coalition’s are consumer protection lawsuits, and their allegations overlap considerably, including the addictive features named, the claims about misleading safety tools, and the focus on young consumers.

Missouri: A civil investigative demand

Missouri’s Attorney General issued a Civil Investigative Demand requiring TikTok to disclose how its algorithm selects and promotes content for children. TikTok must explain how the platform’s primary recommendation system evaluates watch time, reactions, and other signals, and whether those signals push inappropriate or harmful content to young users.

The demand also requires TikTok to disclose its strategies to attract, retain, and increase activity among young users, including internal business discussions and communications that reveal whether TikTok designed its features to hold the attention of younger users or increase screen time. TikTok must account for its handling of dangerous online challenges, the presence of fake accounts, and any coordination with outside organisations involved in youth safety.

On data, the investigation will examine how TikTok collects and uses information from children under 13, minors under 18, and young adults under 24. TikTok must produce its internal methods for determining a user’s age, the safeguards it claims to apply, and the actual enforcement of those policies. Internal research into how children engage with the platform, including any studies on youth mental health and exposure to harmful material, must also be produced.

TikTok must comply and produce all required documents by November 13, 2026. Failure to comply may result in legal penalties.

Arizona: A lawsuit under the Arizona Consumer Fraud Act

Arizona AG Kris Mayes filed a consumer protection lawsuit in Maricopa County Superior Court alleging widespread violations of the Arizona Consumer Fraud Act. According to the complaint, TikTok engineered its platform to maximise compulsive use among minors, including children under 13, by deploying specific manipulative design tactics: infinite scrolling, autoplay, reward loops featuring harmful content, social comparison metrics, push notifications, and appearance-altering filters.

The complaint alleges these features were created to attract young users and keep them engaged as long and as often as possible so that TikTok could profit from their data. It also alleges TikTok concealed the mental, physical, and emotional health risks associated with these design choices, including increased risks of depression, anxiety, sleep disruption, disordered eating, body image distress, and self-harm.

The complaint further alleges that TikTok knowingly permitted extensive under-13 use of its platform despite publicly claiming to bar such users, and that its recommendation algorithms expose minors to increasingly extreme or age-inappropriate content. It describes TikTok’s content moderation practices as inadequate to block much of the dangerous material on the platform.

On safety tools, the complaint alleges TikTok marketed a 60-minute screen time limit it knew would not reduce minors’ usage, and that it used placebo testing in which it misrepresented the existence of safety features to some users.

New York and 13 other jurisdictions: Coordinated consumer protection lawsuits

New York AG Letitia James and California AG Rob Bonta co-led a bipartisan coalition of 14 attorneys general in filing separate consumer protection lawsuits against TikTok, each under their own state laws. Many of the allegations overlap with Arizona’s, including the addictive features named and the claims about the 60-minute screen time limit. The other members of the coalition are Illinois, Kentucky, Louisiana, Massachusetts, Mississippi, New Jersey, North Carolina, Oregon, South Carolina, Vermont, Washington, and the District of Columbia. Each filed in their own state jurisdiction.

According to the lawsuits, TikTok’s underlying business model focuses on maximising young users’ time on the platform to boost revenue from targeted advertising, and its content recommendation system is designed to keep minors on the platform as long as possible, despite the dangers of compulsive use.

The addictive features named include around-the-clock notifications that disrupt sleep, autoplay with no option to disable it, time-limited stories and live content that entice immediate viewing, highlighted likes and comments that affect self-esteem, and beauty filters that lower young users’ body image. Studies cited in the lawsuits report that 50% of girls believe they do not look good without editing their features, and 77% say they try to change or hide at least one part of their body using these filters.

The coalition also points to dangerous TikTok challenges. A 15-year-old boy died in Manhattan while subway surfing, a trend his mother later found videos about on his TikTok account. The lawsuits also cite the Kia Challenge, videos showing users how to start and steal certain Kia and Hyundai models, which they say has led to thousands of car thefts. In October 2022, four teenagers were killed in a car crash in Buffalo that police suspect was the result of the challenge.

On data, the lawsuits allege TikTok violated COPPA by collecting and monetising data from users under 13 without parental consent. Researchers estimate that 35% of TikTok’s US ad revenue is derived from children and teenagers.

On safety tools, the coalition alleges TikTok misrepresented its 60-minute screen time limit. According to the lawsuits, after 60 minutes teens are simply prompted to enter a passcode to continue watching. The coalition also alleges that TikTok’s Refresh and Restricted Mode features do not work as claimed, and that the platform failed to warn young users about the dangers of its beauty filters.

The lawsuits seek to stop these practices and to impose financial penalties, including disgorgement of profits and damages for harmed users.

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