加尔蒙诉谷歌有限责任公司案

Trenton Garmon, a pro se plaintiff and attorney who had previously represented former Alabama Supreme Court Justice Roy Moore, filed suit against Google LLC and Alphabet Inc. in the U.S. District Court for the Northern District of Alabama. Garmon alleged that when users searched his name on Google, the search results displayed negative articles about him while suppressing positive ones, which he claimed constituted defamation and violated Alabama's Right of Publicity Statute. He sought $8 billion in damages and injunctive relief. The court had previously dismissed Garmon's first amended complaint for failure to state a claim and allowed him to amend. Garmon filed a third amended complaint, and Google moved to dismiss with prejudice.

On July 1, 2025, Judge Corey L. Maze granted Google's motion to dismiss and dismissed the case with prejudice. The court found that Garmon failed to allege facts showing Google used his identity for one of the four commercial purposes required under the Alabama statute. The court also dismissed the defamation claim, as Garmon did not plead sufficient factual content to state a plausible claim for relief. Garmon filed a notice of appeal on July 24, 2025.

Whether Google's search engine results—displaying images, links, and articles about a person when that person's name is searched—constitute (1) a violation of Alabama's Right of Publicity Statute, which prohibits commercial use of a person's identity without consent for advertising, selling, fundraising, or false endorsement; and (2) defamation, based on Garmon's allegation that Google uses a "negative algorithm" that intentionally promotes negative stories while suppressing positive ones.

The case highlights the challenges pro se litigants face in pleading viable claims against large technology companies, particularly regarding search engine algorithms and defamation. It also underscores the limits of state right of publicity laws when applied to internet search results, as courts have consistently held that merely displaying search results does not constitute commercial use under such statutes. Legal commentators noted the case as an example of unsuccessful attempts to hold search engines liable for the content of organic search results. The case also illustrates the broader societal debate over whether tech companies' algorithms can be held accountable for the prominence of negative content about individuals.