In Forman v. Henkin, the First Appellate Division of the Supreme Court of New York clarified New York’s rules for social media discovery. The court held that if a party seeks to gain access to a private social media account as part of the discovery process, that party must first make a threshold showing of “relevance” prior to being granted access to the account. To make such a showing, the party requesting discovery must find publicly available social media posts from the opposing party that are somehow relevant to the opposing party’s claim or defense. Following a discussion of the court’s holding, this Comment discusses the implications of the court’s decision on the broader discovery process and calls for a reconsideration of the rules for social media discovery.