Byrd v. Google Headquarters
- Edward Davila
- 5:21-cv-00571
- U.S. District Court · Northern District of California
- 3
In Byrd v. Google, Judge Davila dismissed the prisoner’s federal civil-rights case and denied a pending motion as moot.
Thomas Byrd’s federal civil-rights action was dismissed, and he was directed to pursue the claims in state court. Google was not treated as a state actor under the federal civil-rights statute.
What happened
Byrd v. Google Headquarters involved Thomas Byrd’s claim that Google published false information and damaging images about him, causing harassment and harm while he was imprisoned. He sued under a federal civil-rights law and sought damages for defamation.
The court ruled that defamation is a state-law claim and that Google was not acting for a state government. Because Byrd did not show a violation of federal law by a state actor, his federal civil-rights claim could not proceed in federal court.
Judge Edward J. Davila dismissed the action for failure to state a claim for relief and directed Byrd to pursue the claims in the appropriate state court. The court also denied as moot Byrd’s motion concerning whether Google should be held in default.
The detailed version
- Byrd v. Google Headquarters · No. 5:21-cv-00571
- Edward Davila
- Apr. 29, 2021
Background
Thomas Byrd, a prisoner in the custody of the Illinois Department of Corrections, filed this case without a lawyer under 42 U.S.C. § 1983, a federal civil-rights statute. He sued “Google Headquarters C.E.O. [and] all media outlets own[ed] by Google.” The court had allowed him to proceed without paying the filing fee.
The original complaint was unsigned. Byrd later filed a signed complaint containing the same allegations, and the court treated that filing as the operative complaint. Byrd alleged that Google published an article containing false facts about his criminal charge for home invasion and aggravated kidnapping. He also alleged that Google posted a picture of him marked with the words “sexual assault,” and used his face with pictures of Batman and Robin while falsely stating that he had told police, “I’m Batman.” He claimed the publication led to verbal harassment by inmates and officers and caused physical and psychological harm. He sought damages for defamation.
Court’s Analysis
The court explained that a claim under Section 1983 requires allegations showing both a violation of a right secured by the Constitution or federal law and action by a person acting under state authority. The court concluded that Byrd’s allegations did not satisfy either requirement. It characterized defamation as a tort that can be pursued under state law, not under Section 1983, and determined that Google was not a state actor.
The court further stated that, even if Byrd’s allegations were true, Google’s conduct amounted to potentially tortious conduct actionable under state law rather than under Section 1983. The court found no independent basis for federal jurisdiction and stated that Byrd must pursue the claim in state court.
Disposition
The action was dismissed for failure to state a claim for relief. The court directed Byrd to pursue the claims in the appropriate state court. It also denied as moot Byrd’s motion for an extension of time to sign and enter an objection concerning whether Google Headquarters should be held in default. The clerk was directed to terminate all pending motions, including that motion, and close the file. Judge Edward J. Davila signed the order.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.