Section 230 Once Again Immunizes Google’s Search Results–Metroka v. PA Law Enforcement
- ICS Provider. Numerous courts have held Google is one.
- Publisher/Speaker Claims. The plaintiff alleged that Google published the search results.
- Third-Party Content. The “information in the Crimewatch post was created by the Lower Moreland Township Police Department, not by Google.”
The court summarizes: “Google has immunity from her state law claims, as it cannot be held liable for search engine results showing a third party’s statement.”
Courts have sometimes struggled with mugshot cases, but the courts are decisive when it comes to Google search results: Google isn’t liable for presenting third-party content in its search results. This court repeatedly cites the Kabbaj case. Some other cases applying Section 230 to search results include:
Maughan v. Google Technology, Inc., 143 Cal. App. 4th 1242 (Cal. App. Ct. 2006); Murawski v. Pataki, 514 F. Supp. 2d 577 (S.D.N.Y. 2007); Shah v. MyLife.Com, Inc., 2012 WL 4863696 (D. Or. 2012); Merritt v. Lexis Nexis, 2012 WL 6725882 (E.D. Mich. 2012); Nieman v. Versuslaw, Inc., 2012 WL 3201931 (C.D. Ill. 2012); Getachew v. Google, Inc., 491 Fed. Appx. 923 (10th Cir. 2012); Mmubango v. Google, Inc., 2013 WL 664231 (E.D. Pa. 2013); O’Kroley v. Fastcase Inc., 831 F.3d 352 (6th Cir. 2016); Fakhrian v. Google Inc., 2016 WL 1650705 (Cal. App. Ct. 2016); Despot v. Baltimore Life Insurance Co., 2016 WL 4148085 (W.D. Pa. 2016); Manchanda v. Google, Inc., 2016 WL 6806250 (S.D.N.Y. 2016); Mosha v. Yandex Inc., 2019 WL 5595037 (S.D.N.Y. 2019); White v. Discovery Communications LLC, 2023 WL 3335417 (Fla. Dist. Ct. App. May 10, 2023)
Case citation: Metroka v. Pennsylvania State Law Enforcement, 2023 WL 3767745 (E.D. Pa. June 1, 2023)