Google Faces Defamation Lawsuit Over AI-Generated False Claims About Activist Starbuck
Conservative activist Robby Starbuck sued Google alleging its Bard, Gemini, and Gemma AI systems generated defamatory falsehoods about him, including rape allegations and white nationalist connections. A Delaware court ruled in 2025 that Starbuck had pleaded sufficient facts to proceed to discovery, rejecting Google's motion to dismiss, though the case remains ongoing.
What happened
Conservative activist Robby Starbuck filed a defamation lawsuit against Google in October 2024, alleging that Bard, Gemini, and Gemma generated false and defamatory statements about him.
According to the lawsuit, the AI systems produced claims that Starbuck had committed rape, sexually assaulted a minor, flown on Jeffrey Epstein's plane, and had a criminal record including stalking and drug charges. The systems also reportedly falsely connected Starbuck to white nationalist Richard Spencer.
Starbuck became aware of inaccuracies in 2023 while using Bard. He alleges Gemini told him the fabricated claims had been shown to 2,843,917 unique users.
Reported impact
Starbuck claims the AI systems have produced defamatory answers to queries about him since 2023, causing reputational and emotional harm.
Starbuck raised concerns about the broader implications, asking on social media: 'Imagine a future where Bard is used to decide whether you get a loan, if you're approved for adoption.'
Index analysis
Google responded that it was unable to replicate the results in its consumer products and attributed the outputs to 'hallucinations' from Bard that were addressed in 2023. Google spokesperson José Castañeda stated that hallucinations are a known issue for all large language models.
Starbuck alleged in the lawsuit that 'Gemini admitted that it was deliberately engineered to damage the reputation of individuals with whom Google executives disagree politically, including Mr. Starbuck.' Google disputed this characterization.
Governance controls
In October 2025, a Delaware court ruled that Starbuck had pleaded sufficient facts to proceed to discovery, rejecting Google's motion to dismiss. Judge Meghan Adams found the allegations 'sufficient to support a claim for emotional distress damages.'
The court found that Starbuck had alleged the outputs were 'published to third parties,' allowing the case to advance. The ultimate outcome depends on whether Starbuck can prove actual malice, a requirement under U.S. defamation law.
Classification
Sources and evidence
This record was researched and written by the Index, based on the following original reporting.