Adams v. Google LLC
- Edward Davila
- 5:25-cv-05020
- U.S. District Court · Northern District of California
- 5
In Lorenzo Adams v. Google LLC, Judge Davila granted Google’s motion to dismiss because a prior small-claims judgment barred Adams’s YouTube-account claims.
Lorenzo Adams’s federal claims against Google over the termination of his NerdBallerTV YouTube channel were dismissed. The court’s order also prevented amendment of the complaint in this case.
What happened
In Lorenzo Adams v. Google LLC, Lorenzo Adams, representing himself, alleged that Google violated its Terms of Service by terminating his YouTube channel, NerdBallerTV. He sought $100,000 for lost sponsorship income. Google asked the court to dismiss the case because Adams had already litigated the same dispute in Small Claims Court.
The court found that the earlier case involved the same channel termination and the same three strikes. It ruled that the Small Claims Court’s final judgment barred Adams from bringing the same claims again and also settled the issue of whether the termination violated the Terms of Service.
Judge Davila granted Google’s motion to dismiss and dismissed the case without leave to amend, meaning Adams could not revise the complaint in this case. The court directed the clerk to close the matter.
The detailed version
- Adams v. Google LLC · No. 5:25-cv-05020
- Edward Davila
- Oct. 20, 2025
Background
Lorenzo Adams, proceeding without a lawyer, sued Google LLC over the termination of his YouTube channel, NerdBallerTV. Adams alleged that Google violated the parties’ Terms of Service after YouTube issued three strikes for alleged violations of its Community Guidelines and then cancelled his account. He alleged that two strikes did not identify the relevant URLs, preventing him from meaningfully challenging them. He sought $100,000 in damages for lost sponsorship income.
Before filing this federal case, Adams had sued Google in Small Claims Court over the same channel termination. That court entered a final judgment on the merits against Adams and stated that Google had complied with its Terms of Service when it permanently suspended his channel.
Google’s Motion
Google moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), arguing that claim preclusion and issue preclusion barred Adams’s claims. Claim preclusion prevents a party from bringing a later case based on the same claims after a final judgment. Issue preclusion prevents a party from relitigating a factual or legal issue that was actually decided in an earlier proceeding.
Court’s Analysis
The court found all three requirements for claim preclusion satisfied: the federal and Small Claims Court cases arose from the same events, the Small Claims Court issued a final judgment on the merits, and the parties were identical. The court also found all four requirements for issue preclusion satisfied. The issue in both proceedings was whether YouTube’s termination of NerdBallerTV violated the Terms of Service; the issue had been actually litigated and decided; Adams had a full and fair opportunity to litigate it; and resolving that issue was necessary to the Small Claims Court’s judgment.
Because the court found Adams’s claims barred by both doctrines, it did not address his arguments that the complaint adequately alleged breach of the implied covenant of good faith and fair dealing, negligent enforcement and misrepresentation, wrongful termination, or business-interruption damages.
Disposition
The court granted Google’s motion to dismiss. It dismissed the case without leave to amend because it found that the pleading could not be cured by alleging additional facts. The clerk was directed to close the matter.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.