Meta Platforms owes New Mexico $25 billion plus interest at 15% a year until the sum is paid, under a 20-page judgment Santa Fe District Court Judge Francis J. Mathew filed today at 10:51 am. The document, titled "Findings of Fact, Conclusions of Law and Judgment," first awards the state $219,498,600,000, the statutory maximum of $5,000 for each of 43,899,720 violations, then reduces it to $25 billion in the same sentence without setting out how the lower figure was reached.

In Short

A judge in New Mexico wrote down why Meta has to pay $25 billion for telling Facebook users things about their data and about content rules that a jury decided were misleading. The written order says the full legal maximum was about $219 billion, charges 15% interest every year until Meta pays, and leaves the question of forcing Meta to change its practices for later. Meta is expected to appeal, and the order gives few details on why $25 billion was the number chosen, which is likely to matter when a higher court looks at it.

What the document is

The PDF is the court's own judgment in State of New Mexico, ex rel. Raúl Torrez, Attorney General v. Meta Platforms, Inc., f/k/a Facebook, Inc., case No. D-101-CV-2021-00132, in the First Judicial District Court for the County of Santa Fe. The clerk's stamp reads "FILED 1st JUDICIAL DISTRICT COURT Santa Fe County 10/21/2026 10:51 AM." It is signed by Francis J. Mathew as District Court Judge and was e-served on counsel.

It has three parts: 59 findings of fact, 19 conclusions of law and a three-paragraph decretal section beginning "IT IS THEREFORE ORDERED, ADJUDGED AND DECREED." The decretal section is short enough to reproduce in full in substance. According to the judgment, "The State is awarded and shall recover a civil penalty against Meta in the amount of $219,498,600,000.00, which penalty is reduced to the amount of $25,000,000,000.00." It continues: "Interest on the penalty shall accrue at the rate of fifteen percent (15%) per annum until paid in full." The third paragraph reads: "The Court will reserve on injunctive relief pending further briefing in this matter."

PPC Land's first report on the ruling, published this evening, was built on news coverage rather than on this document. It noted that "Neither report quotes any other passage of the order, and neither says whether the order includes injunctive terms." The judgment answers that second point: there are no injunctive terms yet, because the court has deferred the question.

How $219.5 billion became $25 billion

The first PPC Land report said, "What separates the two numbers in the Reuters account is the most striking detail of the day." The judgment confirms both numbers and shows that the gap is not explained in the text.

The maximum is a straight multiplication. According to conclusion of law 3, "The State is entitled to recover a civil penalty not exceeding five thousand dollars ($5,000.00) per violation found by the Jury pursuant to § 57-12-11, NMSA 1978, of the Act." Conclusion 7 then states the result: "The State is entitled to penalties pursuant under the Act pursuant to § 57-12-11, supra, in the amount of $219,498,600,000.00 ($5,000.00/ea. x 43,899,720 violations)." Conclusion 18 goes further, finding that the trial record supports "the highest level of penalty allowed by the New Mexico Unfair Practices Act - $5,000 per violation found by the jury."

Then the decretal paragraph cuts the figure to $25 billion. Nothing in the 19 conclusions of law names a per-violation rate below $5,000, a percentage reduction, a benchmark the court adopted, or a reason for selecting $25 billion over the state's requested $35 billion to $40 billion or Meta's proposed cap of about $3.4 billion. The judgment does not mention either party's proposal at all. The only proportionality argument it addresses directly is Meta's reliance on the Federal Trade Commission's 2019 settlement, which it rejects as a yardstick (see below).

The published article's own arithmetic still holds against the document. "On PPC Land's own calculation, $25 billion spread across 43,899,720 violations works out to about $569 per violation, or roughly 11.4% of the statutory ceiling," it said. On PPC Land's calculation from the judgment's exact figures, the reduced award equals $569.48 per violation and 11.39% of the $219,498,600,000 maximum.

The violations the penalty does not count

The jury actually found more violations than the court multiplied. According to finding of fact 3, "The Jury has found that Meta has committed 43,899,720 willful violations of the New Mexico Unfair Practices Act (the 'Act') by unfair or deceptive trade practices and 5 willful violations by unconscionable trade practices for a total of 43,899,725 willful violations." The penalty calculation in conclusion 7 uses 43,899,720 only. The five unconscionability findings appear instead as aggravating factors: conclusion 9 says the jury's answers to "Questions 30 through 34" establish that Facebook "also engaged willfully in unconscionable trade practices in each of the five subject areas submitted to the jury."

Meta's revenue in the findings

The court put Meta's own financial statements into the record. According to finding 59, "According to Meta's Annual Form 10-K filed with the United States Securities and Exchange Commission for the Year 2025, Meta had Gross Revenues of $200,966,000,000 and Total Stockholders' Equity of $217,243,000,000." Conclusion 12 adds that Facebook "has created a business that in 2025 was worth approximately $1.7 trillion, with yearly revenues of $200 billion."

By PPC Land's calculation, the statutory maximum of $219.5 billion exceeds both Meta's 2025 revenue and its stockholders' equity as stated in the judgment. The reduced $25 billion equals 12.4% of the 2025 revenue figure and 11.5% of the equity figure. The judgment does not say whether those ratios played any part in the reduction.

Fifteen percent a year

The interest term is the provision with the most immediate financial weight, and it received no coverage in the news reports on which PPC Land's first article relied. That article, quoting the Associated Press, said "interest on the penalty would accrue during an appeal." The judgment sets the rate: 15% per annum "until paid in full."

On PPC Land's calculation, 15% of $25 billion is $3.75 billion a year, or about $10.3 million a day, before any compounding. The judgment does not say whether interest is simple or compound or from what date it runs beyond the words "until paid in full." Measured against Meta's own position at the October 1 hearing, the arithmetic is stark: one year of interest at that rate would exceed the roughly $3.4 billion cap Meta proposed for the entire penalty, according to the published article's account of the AP report.

The judgment contains no payment schedule, no deadline for payment, no instruction on where the money goes and no terms for a stay or bond pending appeal. The earlier reports that the money is destined for New Mexico's schools came from the AP and from Attorney General Raúl Torrez; this document does not address it. PPC Land reported in September that Meta had posted a $1.8 billion bond while appealing earlier judgments and had not paid the $375 million penalty from March. In the separate youth safety case, the August abatement order tolled its compliance period during any appeal provided Meta posted a supersedeas bond. Nothing comparable appears in today's judgment.

The counting method, in the court's words

The published article identified the likely battleground. "The most likely target on appeal is the violation count itself," it said. The judgment sets out the method the jury used and the court adopted.

According to finding 7, "Facebook had 1,386,648 New Mexico monthly active users as of June 30, 2020. PX 591. There are approximately 2,100,000 people in New Mexico in total, which represents the expected or reasonably anticipated audience for Facebook's public representations." Finding 14 explains that "Pursuant to the Court's instructions, the jury determined for each representation the number of New Mexicans who were part of its reasonably expected or anticipated audience. The jury found either 1,386,648 or 2,100,000 violations for each of the 26 representations that it found to be unlawful and willful."

So every violation is one person in an audience, not one person shown to have been misled or harmed. The statutory damages structure of the Act makes this possible: the penalty attaches per violation, and the judgment's findings do not rest on proof that any individual saw a given statement. Meta attorney Matt Nicholson told the court on October 1 that "The jury didn't make findings that any New Mexican heard or saw these statements, or was harmed by them," according to the AP report quoted in PPC Land's first article. The judgment does not respond to that argument by name. Its answer, in effect, is the "reasonably expected or anticipated audience" standard that the court gave the jury.

How the 26 statements break down

The findings give violation totals for two of the five subject areas and statement counts for all five. By PPC Land's calculation, the remaining totals follow from the fact that each statement carried one of only two values.

  • Users' control of data: six statements, all found unlawful and willful, for 10,459,944 violations (finding 16). That is three statements at 1,386,648 and three at 2,100,000, on PPC Land's arithmetic.
  • Friends data and the App Developer Investigation: ten statements, Questions 20 through 29, all found unlawful and willful, for 18,146,592 violations (finding 21), or 41.3% of the total. Four at 1,386,648 and six at 2,100,000, on PPC Land's arithmetic.
  • Misinformation: two statements found unlawful and willful (finding 37).
  • Hate speech: five statements found unlawful and willful (finding 37).
  • Equal enforcement of Community Standards: all three statements found unlawful and willful (finding 45).

The three content categories together account for the remaining 15,293,184 violations. Across all 26 statements, 15 carry the Facebook-user figure and 11 the state-population figure, which matches PPC Land's September reading of the verdict form.

One discrepancy needs flagging. PPC Land's September breakdown of the verdict form, as summarized by the site, put three of four misinformation statements in the unlawful column. The judgment says two. The court's figure is the one consistent with the arithmetic: the 3,486,648 misinformation violations reported in September equal exactly one statement at 1,386,648 plus one at 2,100,000, and the five categories then sum to 26 statements, the number both the judgment and Reuters give.

The judgment also helps reconcile a conflict the first article could not resolve. The AP said jurors assessed Facebook's conduct "34 separate times," while Reuters described 29 statements. The judgment refers to "Questions 20 through 29" for the friends-data statements and "Questions 30 through 34" for unconscionability. On PPC Land's reading, which the judgment does not state outright, the verdict form carried 34 questions: 29 on individual statements and five on unconscionability, one for each subject area.

What the court found about data

The bulk of the findings concern data access and the investigation Facebook promised after Cambridge Analytica. For an advertising audience, these are the passages with the most direct bearing on how targeting data has been governed.

The business model

According to finding 17, "Facebook's core business and primary source of revenue is generated from the sale of advertising to third parties that is targeted at Facebook's users based on their personal information." The court recorded testimony from Dr. Calum Matheson that Facebook "sell[s] everything but your name," and found that "Facebook witness Isabella Leone likewise confirmed that the advertising platform requires user data to function, and that users can neither stop Facebook's collection of their data nor turn off ads."

That finding bears on one of the statements at trial. PPC Land reported in September that the jury found willfully deceptive a statement Sheryl Sandberg made on the January 30, 2019 earnings call: "We don't sell your data and we don't tell advertisers who you are." Meta's position, as reported by Reuters and quoted in the first PPC Land article, was that "The evidence showed that Meta does not sell user data."

Privacy settings

Finding 18 says "Facebook's privacy settings do not provide users with meaningful control over their data in many ways." It quotes testimony from Dr. Egelman that audience drop-down menus have "no bearing on what developers can pull from your profile or whether they could even read this post when they communicate with the API, because that's a totally separate set of Facebook privacy settings that studies have regularly shown most users have no idea those exist."

Finding 19 quotes a private email from Mark Zuckerberg to Chris Cox, exhibit PX 670, in which Zuckerberg wrote that users "probably don't understand their current privacy settings or care about who sees their updates." The court quotes a plan from the same exhibit: "Give them a chance to change their privacy settings but obviously don't encourage it. Roll out search such that stream info is available but the names are perhaps somewhat obscured ... Over time we'll add back in the last names once we set the proper user expectation." The judgment says this was done "so that Facebook could better compete with one of its main rivals, Twitter." The exhibit is not dated in the judgment.

Friend sharing and the exemptions

Before 2014, according to finding 22, Facebook let third-party app developers access data on "the friends of those users, even if those users were unaware that their personal information was being shared." In 2014 Facebook announced an end to "friend sharing," with a transition period ending in May 2015 (finding 23). The court found that "more than a year before the announcement, Facebook was already planning to create exemptions for favored business partners" (finding 24), and that "These exemptions were not disclosed to users, despite promises that 'everyone' would be subject to restricted friends sharing permissions" (finding 25). Conclusion 14 says the purpose was "to secretly continue access for its favored business partners without informing users in order to avoid losing revenue."

The App Developer Investigation in numbers

After Cambridge Analytica became public in March 2018, Facebook made five public commitments, according to finding 26: to investigate all apps with access to large amounts of data before the 2014 change, to audit apps with suspicious activity, to ban developers found misusing data, to ensure deletion of improperly obtained data and to notify all affected users. (The finding's opening sentence appears to be missing a word, reading "Facebook made a number of user data on its platform.") The resulting effort, the App Developer Investigation or ADI, ran from approximately March 2018 to March 2021 (finding 27).

The findings measure the gap between promise and result in specific figures:

  • Audits: "Over the entire three-year ADI, however, Facebook conducted only 14 forensic data 'audits'" (finding 29). The court quotes the auditor's own disclaimer from exhibit DX 512: "We have not sought to confirm the accuracy of the data or the information and explanations provided by the company."
  • Bans: internal materials "identified approximately 116 developers that Facebook ultimately banned, corresponding to approximately 125,000 separate apps" (finding 30).
  • Deletion: Facebook "generally relied on developers to certify that data had been deleted rather than independently verifying deletion" (finding 31). The court quotes exhibit PX 356 acknowledging that "[t]here is no reasonable enforcement/verification approach" and that the policy goal was in part "to optimize for external optics."
  • Notification: "Facebook only notified users of two apps, out of the thousands that were found to have been misusing data" (finding 32), after a decision "to narrow Facebook's internal definition of data misuse so that Facebook would not have to notify as many people due to the operational burden of doing so."

Finding 33 says the investigation identified "at least 2,000 unique apps associated with data misuse that should have triggered a user notification." It lists 234 apps engaged in bulk friends' data collection during the deprecation period, 671 that kept access to friends' data after the May 2015 cutoff, 358 collecting data without a valid privacy policy and 1,549 others that investigators "appeared to suspect of data misuse but did not act upon." Those categories add up to 2,812 by PPC Land's count; the judgment does not say whether any apps fall into more than one.

The New Mexico figures follow in finding 34. Of the apps identified, Facebook could associate 1,585 with New Mexico accounts, and those apps "affected the data of at least 1,146,225 New Mexican Facebook users." That is 82.7% of the 1,386,648 monthly active users, by PPC Land's calculation; the court described it as exceeding 80 percent and found that, extrapolated, "nearly all New Mexican Facebook users were affected by data misuse that Facebook was aware of and chose not to inform them about."

Two quotations from senior staff frame the findings. Finding 35 cites a private email from Sandberg, sent "immediately after the Cambridge Analytica scandal became public," stating that "there were a MILLION developers with access to the data [and w]e are going to have many many many more moments like this in the next months and year." Finding 36 says a September 2019 internal legal assessment concluded Facebook "was not in a position to say that it had fulfilled its public commitment concerning the ADI," and that the investigation was shut down in March 2021 without public announcement. It quotes a Facebook corporate representative testifying that "as far as the public is concerned, nobody else remembers the ADI."

What the court found about content

The content findings matter to brand safety teams because they concern how enforcement actually worked for high-profile accounts.

Findings 38 to 40 describe internal research. One test-user study found "Facebook recommended groups and pages containing known misinformation" (PX 542). Research admitted as PX 241 "found a greater concentration of false content in top performing advertising content than in top performing Facebook content generally." According to finding 41, Facebook "chose to not release the negative underlying data to outside academics, as it had originally planned."

The longest passage concerns CrossCheck, also called XCheck. According to finding 46, it was a system "through which certain accounts received treatment different from that applied to ordinary accounts before enforcement occurred." For "business partners, celebrities and influencers on these lists," content "could remain publicly accessible while undergoing the additional review" (finding 47). Facebook told its Oversight Board that the average time to a final decision for US accounts under CrossCheck review was "approximately twelve days" (finding 48). The court quotes a May 31, 2020 document from Guy Rosen, head of the Integrity division: "today we effectively delay enforcement for policy-violating content for xcheck as it remains up and accrues VPVs while we take another look / do outreach / prepare comms." Finding 42 adds that CrossCheck "often caused content that violated Facebook's Misinformation & Harm policy to stay up for extended periods, accruing millions of views."

Finding 43 describes an episode involving Monika Bickert and ProPublica, in which, according to the court, Bickert "deliberately withheld information about Facebook's failure to enforce against hate speech that had been reported over 2,000 times," despite acknowledging internally that the violation was "not an edge case." After the meeting, the court says, Sandberg wrote "This is awesome." about the lack of press follow-up. Finding 50 records testimony from Samidh Chakrabarti, former head of Civic Integrity, that he viewed CrossCheck "as inconsistent with the principle of equal treatment."

The constitutional reasoning

Meta's argument for a lower figure, as the AP reported it and PPC Land's first article quoted, was that a much larger award "would violate due process, was unconstitutional and would not hold up under appeal." The judgment addresses the two federal constitutional limits in brief terms.

On the Excessive Fines Clause, conclusion 6 says only: "The United States Supreme Court has not held that the Eighth Amendment applies to corporations," citing Browning-Ferris Industries of Vermont v. Kelco Disposal (1989). The judgment does not go on to apply an excessive-fines test in the alternative.

On due process, conclusion 11 relies on St. Louis, Iron Mountain & Southern Railway Co. v. Williams (1919), under which state penalties exceed constitutional limits "only where the penalty prescribed is so severe and oppressive as to be wholly disproportioned to the offense and obviously unreasonable." The court adds that "There is no bright line rule for determining what is reasonable" and cites a South Carolina ruling that upheld per-violation penalties of $100 to $2,000 against a due process challenge. Conclusion 10 sets the test the court applied: "Where a company engages in a systematic, years'-long campaign of lies and deception, a substantial verdict is warranted, so long as the penalty bears a rational relationship to the scheme in which the defendant engaged."

Conclusions 4 and 5 frame the Act as remedial. The court quotes New Mexico Supreme Court authority that "monetary assessments are traditionally a form of civil remedy" and that "[a]lthough a civil penalty may cause a degree of punishment for the defendant, such a subjective effect cannot override the legislation's primarily remedial purpose." Conclusion 17 cites a federal False Claims Act ruling that "penalties that fall squarely within the boundaries set by [the legislature] deserve a strong presumption of constitutionality, because the statutory range reflects the considered legislative judgment as to what is excessive."

The comparators the court chose are much smaller in absolute terms. It cites a New Jersey federal ruling that upheld $8,000 for each of 159,574 false claims, a total of $1,276,592,000, and an Eleventh Circuit case that upheld a $1,179,000 civil penalty against alleged harm of $755.54 across 214 instances of fraud. By PPC Land's calculation, the New Mexico judgment's effective rate of about $569 per violation is far below the $8,000 per claim in the first of those cases, while its total is nearly 20 times higher.

On procedure, conclusion 19 states that "Facebook received notice of the claims against it and a full opportunity to defend against liability, willfulness, and the number of violations during a thirteen-day jury trial." It quotes the court's own post-verdict remark that Facebook "had all the incentive that was required to defend this case vigorously" and "did defend vigorously."

The FTC settlement as a benchmark

Finding 5 records that "Meta refers to other penalty assessments for purposes of assessing proportionality, specifically the FTC's settlement with Meta and the $5 billion civil penalties which it agreed to pay, but the settlement cannot be viewed in a vacuum." The court says any comparison must include the FTC's original complaint, the subsequent consent agreement and the litigation over alleged violations of both, citing Meta Platforms, Inc. v. Federal Trade Commission, 723 F.Supp.3d 64 (D.D.C. 2024) and the 2011 FTC matter No. 092 3184. Finding 6 then concludes: "Penalties, consent agreements and decrees have not deterred Meta from using deceptive trade practices in its representations to the citizens of New Mexico in violation of New Mexico's Act." Finding 15 lists "the violations of the Federal Trade Commission consent agreements, settlements, orders and decrees" among the aggravating circumstances.

The FTC benchmark has a long history in PPC Land's coverage. Meta's board approved the $5 billion settlement and its 20-year consent decree in 2019, and the company later paid $190 million to settle a shareholder derivative suit rooted in the same privacy failures.

Corrections to the first report

Checked against the judgment, the published article's core figures stand. Its $25 billion amount, the "more than $219 billion" maximum attributed to Reuters, the 43 million-plus violation count, the case number and the Unfair Practices Act all match. The quotation Reuters attributed to the judge, "Facebook's wrongdoing - over the course of years and systematically broadcast to the public - goes to the heart of Facebook's core business practices," appears in conclusion of law 17.

Several points need updating or correcting:

  • Injunction. The first article said neither report addressed injunctive terms and that "the business-practice consequences of the case remain unclear." The judgment reserves injunctive relief "pending further briefing." No injunction has been granted or denied.
  • Form of the decision. The first article said "Neither says whether a final judgment has been entered, which matters for when appeal deadlines begin to run." The document is captioned as a judgment and contains decretal language. Because injunctive relief is expressly reserved, the judgment leaves at least one claim for relief undecided; the document does not say how that affects the timing of an appeal.
  • Interest. The first article reported only that interest "would accrue during an appeal." The rate is 15% a year, until paid.
  • Destination of the money. The judgment does not say where the penalty goes. The schools earmark rests on the AP report and on Torrez.
  • Statements. The 26 unlawful statements break down as six on data control, ten on friends data and the ADI, two on misinformation, five on hate speech and three on equal enforcement. PPC Land's September tally of three misinformation statements is inconsistent with the judgment and with the reported violation figures.
  • Jury date and trial length. The judgment does not date the verdict. It describes a "thirteen-day jury trial" and says the parties stipulated to a 12-person jury in an order entered on August 21, 2025.

Why it matters for marketers

The published article argued that if the counting method survives appeal, "public statements about data handling - in press interviews, blog posts and executive remarks - carry a liability that scales with reach." The judgment makes that mechanism concrete. Earnings calls, Newsroom posts, television interviews, print interviews and conference remarks are all listed in finding 9 as channels through which the unlawful representations reached the public, and finding 10 names Zuckerberg and Sandberg personally.

The judgment also connects the case to targeting more directly than the news reports did. Its findings describe the advertising business as dependent on personal data, describe users as unable to stop collection or turn off ads, and set out the gap between Facebook's public account of developer data access and its internal records. Those findings were made by a trial court on a contested record and remain subject to appeal.

What the judgment leaves open is equally significant. It does not explain the $25 billion figure, which gives an appellate court little reasoning to review on the size of the award. It does not resolve injunctive relief, so any conduct remedies, including those that could affect how Meta handles data in New Mexico, are still to come. And it sets an interest rate that, on PPC Land's arithmetic, adds more than $3.7 billion to Meta's exposure for each year the case remains unpaid.

Timeline

Summary

Who: Meta Platforms, formerly Facebook; the State of New Mexico, acting through Attorney General Raúl Torrez; and Judge Francis J. Mathew of the First Judicial District Court for Santa Fe County. The findings name Mark Zuckerberg, Sheryl Sandberg, Chris Cox, Guy Rosen, Monika Bickert and others.

What: A 20-page judgment that awards New Mexico $219,498,600,000 under the Unfair Practices Act, reduces it to $25 billion without a stated method, imposes interest at 15% a year until payment, and reserves injunctive relief for further briefing. Its 59 findings of fact cover Facebook's data access practices, the App Developer Investigation after Cambridge Analytica, and the CrossCheck enforcement system.

When: Filed today, October 21, 2026, at 10:51 am. The jury returned its verdict on September 25, 2026, after a thirteen-day trial; the statements at issue date from May 24, 2010 to August 18, 2021.

Where: The First Judicial District Court, Santa Fe County, New Mexico, case No. D-101-CV-2021-00132.

Why: The jury found 26 public statements by Facebook willfully deceptive and counted each New Mexican in their expected audience as a separate violation. The court held that the scale, duration and senior involvement in the conduct supported the statutory maximum, then reduced the award. The unexplained reduction, the per-audience count and the 15% interest rate are the points most likely to shape Meta's appeal.