In O’Kroley v Fast Case, Inc., the Sixth Circuit rejected a claim brought by Colin O’Kroley who googled himself and did not like the results because, on the summary page, some litigation that he brought was adjoined to a case about indecency with a minor. In response, he filed a suit seeking $19 trillion against Google and other defendants for a variety of claims. The Sixth Circuit found many of his claims barred by the Communications Decency Act, which insulates interactive computer services from certain types of lawsuits (such as this one). Because the plaintiff attacked how Google displayed the search results, the Sixth Circuit found this covered by the Communications Decency Act even though Google performed some automated editorial acts on the content. Therefore, Google was protected from liability by the CDA.

The Court also found other arguments that were raised, such as a request for violation of the Eighteenth Amendment (prohibiting alcohol that was since repealed), to be frivolous. The Sixth Circuit concluded by noting the somewhat ironic result of Mr. O’Kroley’s quest: “Since filing the case, Google users searching for “Colin O’Kroley” no longer see the objectionable search result at the top of the list. Now the top hits all involve this case (there is even a Wikipedia entry on it). So: Even assuming two premises of this lawsuit are true—that there are Internet users other than Colin O’Kroley searching “Colin O’Kroley” and that they look only at the Google previews rather than clicking on and exploring the links—it’s not likely that anyone will ever see the offending listing at the root of this lawsuit. Each age has its own form of self-help.”