Well, I don't think that's been established in court, but it's probably not even important in the case of FB, Twitter and YouTube because every user agrees to the TOS as a condition of using the service.
Section 230 or not someone suing would have to show the company breached their own terms of service. I'm not up on any of the TOS agreements but I'd wager the techs' have protected themselves pretty well.
It has.
but it's probably not even important in the case of FB, Twitter and YouTube because every user agrees to the TOS
TOS has nothing to do with it. If they lose their 230 no TOS is going to protect them.