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Fla. L. Weekly D1830aTop of Form
Fla. L. Weekly D1830aTop of Form
Judges
— Disqualification — Prohibition — Fact that trial judge is a Facebook
“friend” with lawyer representing a potential witness and potential party in
pending litigation is not valid basis for disqualification of judge — Conflict
certified
— Disqualification — Prohibition — Fact that trial judge is a Facebook
“friend” with lawyer representing a potential witness and potential party in
pending litigation is not valid basis for disqualification of judge — Conflict
certified
LAW OFFICES OF HERSSEIN AND
HERSSEIN, P.A., etc., et al., Petitioners, v. UNITED SERVICES AUTOMOBILE
ASSOCIATION, Respondent. 3rd District. Case No. 3D17-1421. L.T. Case No.
15-15825. August 23, 2017. A Case of Original Jurisdiction — Prohibition.
Counsel: Herssein Law Group, and Reuven Herssein, for petitioners. Shutts &
Bowen LLP, and Frank A. Zacherl and Patrick G. Brugger, for respondent.
HERSSEIN, P.A., etc., et al., Petitioners, v. UNITED SERVICES AUTOMOBILE
ASSOCIATION, Respondent. 3rd District. Case No. 3D17-1421. L.T. Case No.
15-15825. August 23, 2017. A Case of Original Jurisdiction — Prohibition.
Counsel: Herssein Law Group, and Reuven Herssein, for petitioners. Shutts &
Bowen LLP, and Frank A. Zacherl and Patrick G. Brugger, for respondent.
(Before FERNANDEZ, LOGUE, and
SCALES, JJ.)
SCALES, JJ.)
(LOGUE, J.) The Law offices of
Herssein and Herssein, P.A. (Herssein Firm) and Reuven Herssein, petition this
court for a writ of prohibition to disqualify the trial court judge below. We
deny the petition. Although Petitioners raise three grounds, we write only to
address the petitioners’ argument that the trial court judge should be
disqualified because the judge is a Facebook “friend” with a lawyer
representing a potential witness and potential party in the pending litigation.
Herssein and Herssein, P.A. (Herssein Firm) and Reuven Herssein, petition this
court for a writ of prohibition to disqualify the trial court judge below. We
deny the petition. Although Petitioners raise three grounds, we write only to
address the petitioners’ argument that the trial court judge should be
disqualified because the judge is a Facebook “friend” with a lawyer
representing a potential witness and potential party in the pending litigation.
The Herssein Firm sued its former
client, United Services Automobile Association (USAA), for breach of contract
and fraud. In the course of the litigation, Herssein accused one of USAA’s
executives of witness tampering and has indicated that the executive is a
potential witness and a potential defendant. In response, USAA hired Israel
Reyes, an ex-circuit court judge, to represent the executive.
client, United Services Automobile Association (USAA), for breach of contract
and fraud. In the course of the litigation, Herssein accused one of USAA’s
executives of witness tampering and has indicated that the executive is a
potential witness and a potential defendant. In response, USAA hired Israel
Reyes, an ex-circuit court judge, to represent the executive.
On June 8, 2017, the Herssein Firm
filed a motion to disqualify the trial judge. The motion is based in part on
the fact that Reyes is listed as a “friend” on the trial judge’s personal
Facebook page. In support of the motion, Iris J. Herssein and Reuven Herssein,
president and vice president of the Herssein Firm, signed affidavits in which
they swore, “[b]ecause [the trial judge] is Facebook friends with Reyes, [the
executive’s] personal attorney, I have a well-grounded fear of not receiving a
fair and impartial trial. Further, based on [the trial judge] being Facebook
friends with Reyes, I . . . believe that Reyes, [the executive’s] lawyer has
influenced [the trial judge].” The trial court denied the disqualification
motion, and the Herssein Firm filed this petition for writ of prohibition.
filed a motion to disqualify the trial judge. The motion is based in part on
the fact that Reyes is listed as a “friend” on the trial judge’s personal
Facebook page. In support of the motion, Iris J. Herssein and Reuven Herssein,
president and vice president of the Herssein Firm, signed affidavits in which
they swore, “[b]ecause [the trial judge] is Facebook friends with Reyes, [the
executive’s] personal attorney, I have a well-grounded fear of not receiving a
fair and impartial trial. Further, based on [the trial judge] being Facebook
friends with Reyes, I . . . believe that Reyes, [the executive’s] lawyer has
influenced [the trial judge].” The trial court denied the disqualification
motion, and the Herssein Firm filed this petition for writ of prohibition.
The test for determining the legal
sufficiency of a motion for disqualification is whether “the facts alleged
(which must be taken as true) would prompt a reasonably prudent person to fear
that he could not get a fair and impartial trial.” Molina v. Perez, 187
So. 3d 909, 909 (Fla. 3d DCA 2016) (quoting Brofman v. Fla. Hearing Care
Ctr., Inc., 703 So. 2d 1191, 1192 (Fla. 4th DCA 1997)). Our review of the
facts focuses on “the reasonable effect on the party seeking disqualification,
not the subjective intent of the judge.” Haas v. Davis, 37 So. 3d 983,
983 (Fla. 3d DCA 2010) (quoting Vivas v. Hartford Fire Ins. Co., 789 So.
2d 1252, 1253 (Fla. 4th DCA 2001)).
sufficiency of a motion for disqualification is whether “the facts alleged
(which must be taken as true) would prompt a reasonably prudent person to fear
that he could not get a fair and impartial trial.” Molina v. Perez, 187
So. 3d 909, 909 (Fla. 3d DCA 2016) (quoting Brofman v. Fla. Hearing Care
Ctr., Inc., 703 So. 2d 1191, 1192 (Fla. 4th DCA 1997)). Our review of the
facts focuses on “the reasonable effect on the party seeking disqualification,
not the subjective intent of the judge.” Haas v. Davis, 37 So. 3d 983,
983 (Fla. 3d DCA 2010) (quoting Vivas v. Hartford Fire Ins. Co., 789 So.
2d 1252, 1253 (Fla. 4th DCA 2001)).
The issue in this case is therefore
whether a reasonably prudent person would fear that he or she could not get a
fair and impartial trial because the judge is a Facebook friend with a lawyer
who represents a potential witness and party to the lawsuit. At the outset, we
note as a general matter, that “allegations of mere ‘friendship’ with an
attorney or an interested party have been deemed insufficient to disqualify a
judge.” Smith v. Santa Rosa Island Auth., 729 So. 2d 944, 946 (Fla. 1st
DCA 1998). Indeed, the Florida Supreme Court has noted:
whether a reasonably prudent person would fear that he or she could not get a
fair and impartial trial because the judge is a Facebook friend with a lawyer
who represents a potential witness and party to the lawsuit. At the outset, we
note as a general matter, that “allegations of mere ‘friendship’ with an
attorney or an interested party have been deemed insufficient to disqualify a
judge.” Smith v. Santa Rosa Island Auth., 729 So. 2d 944, 946 (Fla. 1st
DCA 1998). Indeed, the Florida Supreme Court has noted:
There are
countless factors which may cause some members of the community to think that a
judge would be biased in favor of a litigant or counsel for a litigant, e.g.,
friendship, member of the same church or religious congregation, neighbors,
former classmates or fraternity brothers. However, such allegations have been
found legally insufficient when asserted in a motion for disqualification.
countless factors which may cause some members of the community to think that a
judge would be biased in favor of a litigant or counsel for a litigant, e.g.,
friendship, member of the same church or religious congregation, neighbors,
former classmates or fraternity brothers. However, such allegations have been
found legally insufficient when asserted in a motion for disqualification.
MacKenzie v. Super Kids Bargain
Store, Inc., 565 So. 2d 1332, 1338 (Fla. 1990).
And as Justice Overton explained in denying a request for recusal, “[i]f
friendship alone with a lawyer or member of a firm is a basis for
disqualification, then most judges in rural and semi-rural areas and many in
metropolitan areas would be subject to disqualification in a large number of
cases.” Hayes v. Rogers, 378 So. 2d 1212, 1220 (Fla. 1979).
Store, Inc., 565 So. 2d 1332, 1338 (Fla. 1990).
And as Justice Overton explained in denying a request for recusal, “[i]f
friendship alone with a lawyer or member of a firm is a basis for
disqualification, then most judges in rural and semi-rural areas and many in
metropolitan areas would be subject to disqualification in a large number of
cases.” Hayes v. Rogers, 378 So. 2d 1212, 1220 (Fla. 1979).
Nevertheless, this authority does
not foreclose the possibility that a relationship between a judge and a lawyer
may, under certain circumstances, warrant disqualification. Indeed, in Domville
v. State, 103 So. 3d 184 (Fla. 4th DCA 2012), the Fourth District held that
recusal was required when a judge was a Facebook “friend” with the prosecutor.
The Fourth District based its holding on a 2009 Judicial Ethics Advisory
Committee Opinion. Fla. JEAC Op. 2009-20 (Nov. 17, 2009). In its Opinion, the
Committee advised that judges were prohibited from adding lawyers who appear
before them as “friends” on their Facebook page or from allowing lawyers who
appear before them to add them as “friends” on the lawyers’ Facebook pages. The
Committee focused on the fact that a judge on Facebook has an active role in
accepting or rejecting potential “friends” or in inviting another to accept
them as “friends.” Id. “It is this selection and communication process,”
the Committee advised, “that violates Cannon 2B, because the judge, by so
doing, conveys or permits others to convey the impression that they are in a
special position to influence the judge.” Id.
not foreclose the possibility that a relationship between a judge and a lawyer
may, under certain circumstances, warrant disqualification. Indeed, in Domville
v. State, 103 So. 3d 184 (Fla. 4th DCA 2012), the Fourth District held that
recusal was required when a judge was a Facebook “friend” with the prosecutor.
The Fourth District based its holding on a 2009 Judicial Ethics Advisory
Committee Opinion. Fla. JEAC Op. 2009-20 (Nov. 17, 2009). In its Opinion, the
Committee advised that judges were prohibited from adding lawyers who appear
before them as “friends” on their Facebook page or from allowing lawyers who
appear before them to add them as “friends” on the lawyers’ Facebook pages. The
Committee focused on the fact that a judge on Facebook has an active role in
accepting or rejecting potential “friends” or in inviting another to accept
them as “friends.” Id. “It is this selection and communication process,”
the Committee advised, “that violates Cannon 2B, because the judge, by so
doing, conveys or permits others to convey the impression that they are in a
special position to influence the judge.” Id.
A minority of the Committee
disagreed. The minority believed that “the listing of lawyers who may appear
before the judge as ‘friends’ on a judge’s social networking page does not
reasonably convey to others the impression that these lawyers are in a special
position to influence the judge.” Id. They reasoned “the term ‘friend’
on social networking sites merely conveys the message that a person so
identified is a contact or acquaintance; and that such an identification does
not convey that a person is a ‘friend’ in the traditional sense, i.e., a person
attached to another person by feelings of affection or personal regard.” Id.
disagreed. The minority believed that “the listing of lawyers who may appear
before the judge as ‘friends’ on a judge’s social networking page does not
reasonably convey to others the impression that these lawyers are in a special
position to influence the judge.” Id. They reasoned “the term ‘friend’
on social networking sites merely conveys the message that a person so
identified is a contact or acquaintance; and that such an identification does
not convey that a person is a ‘friend’ in the traditional sense, i.e., a person
attached to another person by feelings of affection or personal regard.” Id.
In 2010, the Committee advised that
candidates for judicial office may add lawyers as “friends” on a social
networking site even if those lawyers would later appear before them should the
candidate be elected. Fla. JEAC Op. 2010-05 (March 19, 2010). It also
reaffirmed, however, the advice in its 2009 advisory opinion that a judge may
not be Facebook “friends” with a lawyer who appears before her, although a minority
believed the committee should recede from its 2009 opinion. See Fla.
JEAC Op. 2010-06 (March 26, 2010).
candidates for judicial office may add lawyers as “friends” on a social
networking site even if those lawyers would later appear before them should the
candidate be elected. Fla. JEAC Op. 2010-05 (March 19, 2010). It also
reaffirmed, however, the advice in its 2009 advisory opinion that a judge may
not be Facebook “friends” with a lawyer who appears before her, although a minority
believed the committee should recede from its 2009 opinion. See Fla.
JEAC Op. 2010-06 (March 26, 2010).
More recently, the Fifth District
signaled disagreement with the Fourth District’s Domville decision. In Chace
v. Loisel, 170 So. 3d 802, 803-04 (Fla. 5th DCA 2014), the Fifth District
held that, in a dissolution of marriage case, a judge who sent the wife a
Facebook friend request during the proceedings, which the wife rejected, made
an ex-parte communication and was required to recuse himself. In so ruling,
however, the Fifth District noted, “[w]e have serious reservations about the
court’s rationale in Domville.” Id. Defining the word “friend” on
Facebook as a “term of art,” the Fifth District explained:
signaled disagreement with the Fourth District’s Domville decision. In Chace
v. Loisel, 170 So. 3d 802, 803-04 (Fla. 5th DCA 2014), the Fifth District
held that, in a dissolution of marriage case, a judge who sent the wife a
Facebook friend request during the proceedings, which the wife rejected, made
an ex-parte communication and was required to recuse himself. In so ruling,
however, the Fifth District noted, “[w]e have serious reservations about the
court’s rationale in Domville.” Id. Defining the word “friend” on
Facebook as a “term of art,” the Fifth District explained:
A number
of words or phrases could more aptly describe the concept, including
acquaintance and, sometimes, virtual stranger. A Facebook friendship does not
necessarily signify the existence of a close relationship. Other than the
public nature of the internet, there is no difference between a Facebook
“friend” and any other friendship a judge might have. Domville‘s logic
would require disqualification in cases involving an acquaintance of a judge.
Particularly in smaller counties, where everyone in the legal community knows
each other, this requirement is unworkable and unnecessary. Requiring
disqualification in such cases does not reflect the true nature of a Facebook
friendship and casts a large net in an effort to catch a minnow.
of words or phrases could more aptly describe the concept, including
acquaintance and, sometimes, virtual stranger. A Facebook friendship does not
necessarily signify the existence of a close relationship. Other than the
public nature of the internet, there is no difference between a Facebook
“friend” and any other friendship a judge might have. Domville‘s logic
would require disqualification in cases involving an acquaintance of a judge.
Particularly in smaller counties, where everyone in the legal community knows
each other, this requirement is unworkable and unnecessary. Requiring
disqualification in such cases does not reflect the true nature of a Facebook
friendship and casts a large net in an effort to catch a minnow.
Id.
We agree with the Fifth District
that “[a] Facebook friendship does not necessarily signify the existence of a
close relationship.” We do so for three reasons. First, as the Kentucky Supreme
Court noted, “some people have thousands of Facebook ‘friends.’ ” Sluss v.
Commonwealth, 381 S.W.3d 215, 222 (Ky. 2012). In Sluss, the Kentucky
Supreme Court held the fact that a juror who was a Facebook “friend” with a
family member of a victim, standing alone, was not enough evidence to presume
juror bias sufficient to require a new trial. In Sluss, the juror in
question had nearly two thousand Facebook “friends.” Id. at 223. Another
recent out-of-state case involved a trial judge with over fifteen hundred
Facebook “friends” who was allegedly a Facebook friend with a potential
witness, a local university basketball coach, who himself had more than
forty-nine hundred Facebook “friends.” State v. Madden, No.
M2012-02473-CCA-R3-CD, 2014 WL 931031, at *1-2 (Tenn. Crim. App. Mar. 11, 2014)
(holding trial judge did not abuse his discretion under Tennessee law in
refusing to recuse himself because he was allegedly Facebook “friends” with
potential witness).1
that “[a] Facebook friendship does not necessarily signify the existence of a
close relationship.” We do so for three reasons. First, as the Kentucky Supreme
Court noted, “some people have thousands of Facebook ‘friends.’ ” Sluss v.
Commonwealth, 381 S.W.3d 215, 222 (Ky. 2012). In Sluss, the Kentucky
Supreme Court held the fact that a juror who was a Facebook “friend” with a
family member of a victim, standing alone, was not enough evidence to presume
juror bias sufficient to require a new trial. In Sluss, the juror in
question had nearly two thousand Facebook “friends.” Id. at 223. Another
recent out-of-state case involved a trial judge with over fifteen hundred
Facebook “friends” who was allegedly a Facebook friend with a potential
witness, a local university basketball coach, who himself had more than
forty-nine hundred Facebook “friends.” State v. Madden, No.
M2012-02473-CCA-R3-CD, 2014 WL 931031, at *1-2 (Tenn. Crim. App. Mar. 11, 2014)
(holding trial judge did not abuse his discretion under Tennessee law in
refusing to recuse himself because he was allegedly Facebook “friends” with
potential witness).1
Second, Facebook members often
cannot recall every person they have accepted as “friends” or who have accepted
them as “friends.” In a recent case, a student, who had over one thousand
Facebook “friends,” did not know he was a Facebook “friend” with another student
he was accused of assaulting. Furey v. Temple Univ., 884 F. Supp. 2d
223, 241 (E.D. Pa. 2012). In another case, a juror did not recognize a victim’s
name even though a member of the victim’s family was one of her over-a-thousand
Facebook “friends.” Slaybaugh v. State, 47 N.E.3d 607, 608 (Ind. 2016)
(affirming trial court’s denial of mistrial when “juror testified she was a
realtor, had more than 1000 ‘friends’ on Facebook — most of whom she had
‘friended’ for networking purposes — but she had not recognized the victim’s
name during voir dire, did not recognize the victim when she testified, and did
not know the victim or her family”).2
cannot recall every person they have accepted as “friends” or who have accepted
them as “friends.” In a recent case, a student, who had over one thousand
Facebook “friends,” did not know he was a Facebook “friend” with another student
he was accused of assaulting. Furey v. Temple Univ., 884 F. Supp. 2d
223, 241 (E.D. Pa. 2012). In another case, a juror did not recognize a victim’s
name even though a member of the victim’s family was one of her over-a-thousand
Facebook “friends.” Slaybaugh v. State, 47 N.E.3d 607, 608 (Ind. 2016)
(affirming trial court’s denial of mistrial when “juror testified she was a
realtor, had more than 1000 ‘friends’ on Facebook — most of whom she had
‘friended’ for networking purposes — but she had not recognized the victim’s
name during voir dire, did not recognize the victim when she testified, and did
not know the victim or her family”).2
Third, many Facebook “friends” are
selected based upon Facebook’s data- mining technology rather than personal
interactions. Facebook data-mines its members’ current list of “friends,”
uploaded contact lists from smart phones and computers, emails, names tagged in
uploaded photographs, internet groups, networks such as schools and employers,
and other publicly or privately available information. This information is
analyzed by proprietary algorithms that predict associations. Facebook then suggests
these “People You May Know” as potential “friends.”3
selected based upon Facebook’s data- mining technology rather than personal
interactions. Facebook data-mines its members’ current list of “friends,”
uploaded contact lists from smart phones and computers, emails, names tagged in
uploaded photographs, internet groups, networks such as schools and employers,
and other publicly or privately available information. This information is
analyzed by proprietary algorithms that predict associations. Facebook then suggests
these “People You May Know” as potential “friends.”3
The use of data mining and
networking algorithms, which are also revolutionizing modern marketing and
national security systems, reflects an astounding development in applied
mathematics; it constitutes a powerful tool to build personal and professional
networks; and it has nothing to do with close or intimate friendships of the
sort that would require recusal. This common method of selecting Facebook
“friends” undermines the rationale of Domville and the 2009 Ethics
Opinion that a judge’s selection of Facebook “friends” necessarily “conveys or
permits others to convey the impression that they are in a special position to
influence the judge.”
networking algorithms, which are also revolutionizing modern marketing and
national security systems, reflects an astounding development in applied
mathematics; it constitutes a powerful tool to build personal and professional
networks; and it has nothing to do with close or intimate friendships of the
sort that would require recusal. This common method of selecting Facebook
“friends” undermines the rationale of Domville and the 2009 Ethics
Opinion that a judge’s selection of Facebook “friends” necessarily “conveys or
permits others to convey the impression that they are in a special position to
influence the judge.”
To be sure, some of a member’s
Facebook “friends” are undoubtedly friends in the classic sense of person for
whom the member feels particular affection and loyalty. The point is, however,
many are not. A random name drawn from a list of Facebook “friends” probably
belongs to casual friend; an acquaintance; an old classmate; a person with whom
the member shares a common hobby; a “friend of a friend;” or even a local
celebrity like a coach. An assumption that all Facebook “friends” rise to the
level of a close relationship that warrants disqualification simply does not
reflect the current nature of this type of electronic social networking.
Facebook “friends” are undoubtedly friends in the classic sense of person for
whom the member feels particular affection and loyalty. The point is, however,
many are not. A random name drawn from a list of Facebook “friends” probably
belongs to casual friend; an acquaintance; an old classmate; a person with whom
the member shares a common hobby; a “friend of a friend;” or even a local
celebrity like a coach. An assumption that all Facebook “friends” rise to the
level of a close relationship that warrants disqualification simply does not
reflect the current nature of this type of electronic social networking.
In fairness to the Fourth District’s
decision in Domville and the Judicial Ethics Advisory Committee’s 2009
opinion, electronic social media is evolving at an exponential rate. Acceptance
as a Facebook “friend” may well once have given the impression of close
friendship and affiliation. Currently, however, the degree of intimacy among
Facebook “friends” varies greatly. The designation of a person as a “friend” on
Facebook does not differentiate between a close friend and a distant
acquaintance. Because a “friend” on a social networking website is not
necessarily a friend in the traditional sense of the word, we hold that the
mere fact that a judge is a Facebook “friend” with a lawyer for a potential
party or witness, without more, does not provide a basis for a well-grounded
fear that the judge cannot be impartial or that the judge is under the
influence of the Facebook “friend.” On this point we respectfully acknowledge
we are in conflict with the opinion of our sister court in Domville.
decision in Domville and the Judicial Ethics Advisory Committee’s 2009
opinion, electronic social media is evolving at an exponential rate. Acceptance
as a Facebook “friend” may well once have given the impression of close
friendship and affiliation. Currently, however, the degree of intimacy among
Facebook “friends” varies greatly. The designation of a person as a “friend” on
Facebook does not differentiate between a close friend and a distant
acquaintance. Because a “friend” on a social networking website is not
necessarily a friend in the traditional sense of the word, we hold that the
mere fact that a judge is a Facebook “friend” with a lawyer for a potential
party or witness, without more, does not provide a basis for a well-grounded
fear that the judge cannot be impartial or that the judge is under the
influence of the Facebook “friend.” On this point we respectfully acknowledge
we are in conflict with the opinion of our sister court in Domville.
Petition denied.
__________________
1See, e.g., Mocombe v. Russell Life Skills & Reading Found.,
Inc., No. 12-60659-CIV, 2014 WL 11531914, at *1 (S.D. Fla. Oct. 31, 2014)
(noting “Plaintiff had more than 5,000 Facebook friends.”); Banken v. Banken,
No. A11-2156, 2013 WL 490677, at *9 (Minn. Ct. App. Feb. 11, 2013) (noting a
party had “more than 1000 friends” on Facebook).
Inc., No. 12-60659-CIV, 2014 WL 11531914, at *1 (S.D. Fla. Oct. 31, 2014)
(noting “Plaintiff had more than 5,000 Facebook friends.”); Banken v. Banken,
No. A11-2156, 2013 WL 490677, at *9 (Minn. Ct. App. Feb. 11, 2013) (noting a
party had “more than 1000 friends” on Facebook).
2Because Facebook members sometimes
cannot be expected to know everyone they have accepted as “friends” or who have
accepted them as “friends,” the American Bar Association, when advising judges
that they should disclose Facebook friendships when appropriate, expressly
advised that a judge need not review his or her list of “friends” when doing
so. American Bar Association, Judge’s Use of Electronic Social Networking
Media, Formal Opinion 462 (Feb. 21, 2013) (“[N]othing requires a judge to
search all of the judge’s ESM [electronic social media] connections if a judge
does not have specific knowledge of an ESM connection that rises to the level
of an actual or perceived problematic relationship with any individual.”).
cannot be expected to know everyone they have accepted as “friends” or who have
accepted them as “friends,” the American Bar Association, when advising judges
that they should disclose Facebook friendships when appropriate, expressly
advised that a judge need not review his or her list of “friends” when doing
so. American Bar Association, Judge’s Use of Electronic Social Networking
Media, Formal Opinion 462 (Feb. 21, 2013) (“[N]othing requires a judge to
search all of the judge’s ESM [electronic social media] connections if a judge
does not have specific knowledge of an ESM connection that rises to the level
of an actual or perceived problematic relationship with any individual.”).
3Facebook, Where do People You May
Know suggestions come from?
https://www.facebook.com/help/163810437015615?helpref=search&sr=1&query=how%20does%20facebook%20come%20up%20with%20friend%20suggestions
(visited August 2, 2017).
Know suggestions come from?
https://www.facebook.com/help/163810437015615?helpref=search&sr=1&query=how%20does%20facebook%20come%20up%20with%20friend%20suggestions
(visited August 2, 2017).
* * *