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Keene v. Google: defamation claim over AI Overviews calling an author a convicted murderer survives dismissal

An author and television producer, the subject of the Apple TV series 'Black Bird', sued Google, alleging that AI Overviews shown for searches about him in May and June 2025 falsely said he was serving a life sentence without parole, in one version for the murders of three women. He says he notified Google three times and received apologies attributing the statements to its AI, yet similar statements kept appearing. On 14 September 2026 the Northern District of Illinois denied Google's motion to dismiss as to two of the four challenged Overviews and dismissed the other two without prejudice. This was a ruling on the pleadings, not a finding that the allegations were proven.

AI System

Google AI Overviews

Google LLC

Occurred

24 May 2025 to 27 Jun 2025

Reported

23 September 2025

Event location

Unknown

Platform

Unknown

What the evidence supports

AI involvement: supported. The statements at issue appeared in Google's AI Overviews, and the court's opinion recites the allegation that Google attributed them to errors by its artificial intelligence. The screenshots are exhibits to the complaint and were not inspected here; the court accepted the allegations as true for the motion to dismiss only.

AI-to-person relation

  • Made a claim about the person

Core relations are communication, acting on someone’s behalf, and depiction or impersonation. Decision and claim relations are retained as contextual cases.

An institution’s AI use. Settings: Everyday life, Privacy, Justice.

Claim status: Documented

The court’s opinion recounts four challenged Google AI Overviews between approximately 24 May and 27 June 2025. The complaint alleges that Overviews 1, 2 and 4 falsely said Keene was serving life without parole, with Overview 2 adding murders of three women. Overview 3 instead said he had been convicted of drug trafficking; the court considered that statement substantially true.

Causal attribution: Allegations of the complaint as recited by the court; accepted as true only for the motion to dismiss.

  • Court opinion (supports): Opinion page 2 lists Overviews 1–4 separately: 1, 2 and 4 concern life without parole; 2 mentions murders of three women; 3 says he was convicted of drug trafficking. The analysis of Overview 3 and conclusion explain its substantial-truth dismissal.
  • Legal commentary (context): Complaint excerpt: statements that he 'is serving a life sentence without parole for multiple convictions' and 'for the murders of 3 women'.

Claim status: Documented

The complaint alleges he notified Google on 27 May, 31 May and after 27 June 2025, that Google apologised each time and attributed the statements to errors by its AI, and that Overviews 1 and 2 were seen by family members, friends and acquaintances.

Causal attribution: Allegations as recited by the court.

  • Court opinion (supports): Page 2: 'Keene complained to Google about the false statements on three occasions ... Google allegedly apologized ... and deemed the statements errors made by its Artificial Intelligence.' and 'AI Overviews 1 and 2 were seen by various family members, friends, and acquaintances.'
  • Legal commentary (context): Complaint excerpt: 27 May 2025 complaint; Google 'privately apologized', attributing the statements to 'an unknown error made by their Artificial Intelligence Platform'.

Claim status: Documented

On 14 September 2026 Judge Thomas M. Durkin denied Google's motion to dismiss the defamation per se claim as to Overviews 1 and 2, holding that the plaintiff, a public figure, had plausibly pleaded actual malice through his three notifications, and dismissed the claims on Overviews 3 (substantially true) and 4 (publication not alleged) without prejudice, with leave to amend by 13 October 2026.

Causal attribution: Court ruling on the pleadings; no finding of liability.

  • Court opinion (supports): Pages 1 and 12: 'that motion is granted in part and denied in part' ... 'the Court denies Google's motion to dismiss AI Overviews 1 and 2, and grants Google's motion to dismiss AI Overviews 3 and 4 without prejudice. Keene may file an amended complaint by October 13, 2026.'
  • Court docket (context): Docket entry 29, 14 September 2026: 'Memorandum Opinion and Order AND Order on Motion to Dismiss'.
  • Legal commentary (supports): Post quoting the opinion's actual-malice and disclaimer holdings.

Claim status: Documented

The suit was filed in the Circuit Court of Cook County on 30 July 2025 and removed by Google to federal court on 22 September 2025.

Causal attribution: Procedural history from the court record.

  • Court opinion (supports): Page 2: 'Keene filed his complaint ... on July 30, 2025, in the Circuit Court of Cook County. Google removed the suit to federal court on September 22, 2025.'
  • Court docket (supports): Docket header: filed 22 September 2025, No. 1:25-cv-11431.

What remains unknown

  • The plaintiff's residence and the locations where the Overviews were generated or viewed are not stated in the inspected records.
  • No damages figure appears in the inspected records.
  • The complaint exhibits (screenshots of the Overviews) were not inspected.
  • The case continues; an amended complaint was due by 13 October 2026.
Source reading, translation and location

Court opinion · en · Source inspected

Memorandum Opinion and Order, ECF No. 29, filed 14 September 2026; PDF read in full via CourtListener RECAP on 2026-09-15.

This source shares an underlying account with another listed source.

Court docket · en · Source inspected

Public docket page read on 2026-09-15.

This source shares an underlying account with another listed source.

Legal commentary · en · Source inspected

Read on 2026-09-15; quotes the opinion.

This source shares an underlying account with another listed source.

Legal commentary · en · Source inspected

Read on 2026-09-15; quotes the complaint at removal.

This source shares an underlying account with another listed source.

Event countries: Unknown. Affected-person countries: Unknown. Court countries: United States.

The AI Overviews were generated online in response to searches; where they were generated or viewed is not stated. The plaintiff's residence is not stated in the inspected records, and the charter does not infer a country from the court. Court: United States District Court for the Northern District of Illinois, after removal from the Circuit Court of Cook County.

Reviewed for publication 2026-09-15: Published on the strength of the court's own opinion and docket, read in full, with legal commentary as context. The plaintiff is a public figure who sued under his own name; allegations are attributed to the complaint and the ruling is limited to the pleadings.

What Happened

The court’s opinion, recounting the complaint’s background, says the plaintiff pleaded guilty to a drug conspiracy in 1997 and, in exchange for a pardon, worked as a prison informant against a suspected serial killer; his conviction was later expunged and his memoir became the Apple TV series 'Black Bird'. In May and June 2025, according to his complaint, Google AI Overviews generated for searches about him stated that he was serving a life sentence without parole, one version adding 'for the murders of three women', and cited a Wikipedia page that said no such thing. He complained to Google on 27 May, 31 May and after 27 June 2025; Google apologised each time and blamed its AI, but similar statements continued to appear. He sued for defamation per se in Cook County on 30 July 2025 and Google removed the case to federal court. On 14 September 2026 the court held that an ordinary user searching for a person's net worth 'is seeking factual information, not AI work product', that linking to a source with correct information does not defeat a defamation claim, and that the three notifications plausibly pleaded actual malice; the claims on two Overviews proceed and two were dismissed without prejudice.

Reported harm

The plaintiff alleges that false AI-generated statements that he was a convicted murderer serving life without parole were shown to searchers, including family, friends and acquaintances, and continued after he notified Google.

Reputational Harm

Outcome

Ongoing

Filed 30 July 2025 in the Circuit Court of Cook County; removed 22 September 2025 to the N.D. Ill. (No. 1:25-cv-11431, Judge Thomas M. Durkin). Motion to dismiss decided 14 September 2026: denied as to AI Overviews 1 and 2 (life sentence without parole; murders of three women), granted without prejudice as to Overview 3 (drug-trafficking conviction held substantially true) and Overview 4 (publication to third parties not alleged); amended complaint due 13 October 2026.

People described

Author, television producer and former FBI operative who sued under his own name

People reported harmed in this case

1 person

0 AI participants · 1 other person harmed

One person is the subject of the alleged defamatory statements and the plaintiff (court opinion). Family and acquaintances who saw the statements are not counted as harmed.

Counted once within this case. The same person may appear in other cases. This count does not establish AI causation.

Tags

#defamation#ai-overviews#google#hallucination#lawsuit#reputational-harm

Cite this case

Compiled per our published methodology: verification statuses, sourcing standards, and corrections process.

APA

NOPE. (2025). Keene v. Google: defamation claim over AI Overviews calling an author a convicted murderer survives dismissal. NOPE: AI and people. https://nope.net/incidents/2025-keene-v-google-ai-overview-defamation

BibTeX

@misc{2025_keene_v_google_ai_overview_defamation,
  title = {Keene v. Google: defamation claim over AI Overviews calling an author a convicted murderer survives dismissal},
  author = {NOPE},
  year = {2025},
  howpublished = {NOPE: AI and people},
  url = {https://nope.net/incidents/2025-keene-v-google-ai-overview-defamation}
}

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