U.S. District Court for the Eastern District of California — State of California
In Kohls v. Bonta, consolidated with suits by X Corp., Rumble and The Babylon Bee, a federal court ruled against both of California's 2024 election deepfake laws. It entered final judgment on August 20, 2025 that AB 2655, the Defending Democracy from Deepfake Deception Act, is preempted by Section 230 as applied to X Corp. and Rumble, and a stipulated order of August 28 bars the Attorney General and Secretary of State from enforcing it against any provider of an interactive computer service, including Facebook, Instagram and YouTube, unless an appeals court vacates that judgment. On August 29, 2025 it held that AB 2839, which restricts materially deceptive election content, facially violates the First Amendment with no part severable, and permanently enjoined the Attorney General and Secretary of State from enforcing it against the plaintiffs, Christopher Kohls, The Babylon Bee and Kelly Chang Rickert.
Key takeaway — how to prevent this
Election deepfake rules are exposed on two fronts: obliging platforms to block or label users' posts runs into Section 230, and restricting or labelling political satire must survive strict First Amendment scrutiny, which AB 2839 failed in full. The injunctions bind the Attorney General and Secretary of State; neither statute has been repealed.
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