2022 Supreme Court term

GONZALEZ v. GOOGLE LLC

Dockets 21-1333Decided
AI-generated independent summary

This educational guide is based on the linked primary sources. It is not a Court publication, is not affiliated with the Court, and is not legal advice.

In brief

Overview

In 2015, Nohemi Gonzalez, a U.S. citizen, was killed in coordinated terrorist attacks in Paris by ISIS.

According to Plaintiffs, plaintiffs alleged that Google, via YouTube, aided, abetted, and conspired with ISIS.

According to United States, the United States, as amicus curiae, urged vacatur of the lower‑court judgment.

The Supreme Court granted certiorari to review the Ninth Circuit's application of §230.

The Court held that the complaint fails to state a claim for aiding and abetting under §2333(d)(2).

Consequently, the Court vacated the judgment below and remanded the case for further consideration.

According to Petitioners (Eric Schnapper), according to Petitioners (Eric Schnapper), section 230(c)(1) distinguishes between claims based on third‑party content and claims based on a company’s own conduct.

According to United States (amicus curiae), according to United States (amicus curiae), the amicus argued that an internet service provider can be sued for its own organizational choices, but such choices do not strip it of §230 liability.

According to United States (amicus curiae), according to United States (amicus curiae), youTube’s own conduct falls outside of §230(c)(1).

Background and question before the Court

In 2015, Nohemi Gonzalez, a U.S. citizen, was killed in coordinated terrorist attacks in Paris by ISIS.

According to Plaintiffs, plaintiffs alleged that Google, via YouTube, aided, abetted, and conspired with ISIS.

What each side argues

United States (Amicus Curiae)

According to United States (amicus curiae), according to United States (amicus curiae), the amicus argued that an internet service provider can be sued for its own organizational choices, but such choices do not strip it of §230 liability.

According to United States (amicus curiae), according to United States (amicus curiae), youTube’s own conduct falls outside of §230(c)(1).

Petitioners (Eric Schnapper)

According to Petitioners (Eric Schnapper), according to Petitioners (Eric Schnapper), section 230(c)(1) distinguishes between claims based on third‑party content and claims based on a company’s own conduct.

What happened at oral argument

Justice Sotomayor asked whether intent and knowledge are required to aid and abet.

Justice Alito asked whether an internet service provider could ever be sued for defamatory content it provides.

Justice Barrett asked whether retweeting is protected by §230(c).

According to Justice Kagan, justice Kagan referenced Justice Thomas’s earlier question about algorithm differences.

Justice Alito asked whether Google’s liability would cause the internet to collapse.

Justice Gorsuch asked, “Is that right in your view?”

Ms. Blatt warned that holding platforms liable for topic headings would render the statute a dead letter.

What the Court decided

The Court held that the complaint fails to state a claim for aiding and abetting under §2333(d)(2).

The Court vacated the judgment below and remanded the case for further consideration.

Why it matters

Source-limited The available primary sources do not support a complete explanation yet.

Terms to know

No glossary terms are available for this guide.

Primary sources

Read the source materials on the official site or open the immutable repository copy used for this guide.

  • 6d83f99606866326b9d0-r1-fe76c1f6e8ed6b17.pdfopinion
  • e04b50e2cc031a2d816e-r1-73e33d103042e1de.pdforal argument transcript

Guide generated September 29, 2026. Automated validation accepted this version.