The Volokh Conspiracy

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Free Speech

The 9 Libel-by-AI Cases in the U.S. Since 2023 (6 Still Going Forward)

|The Volokh Conspiracy |


  1. Walters v. Openai, L.L.C. (Ga. Super.): No liability (summary judgment), because of the peculiar facts of the case.
  2. Battle v. Microsoft Corp. (D. Md.): Sent to arbitration, and resolved there.
  3. Starbuck v. Meta Platforms (Del. Super.): Settled.
  4. Keene v. Google LLC (N.D. Ill.): Motion to dismiss denied, case can go forward.
  5. Starbuck v. Google (Del. Super.): Motion to dismiss denied, case can go forward.
  6. LTL LED, LLC v. Google LLC (Minn. Dist.): Case going forward, Google failed to properly get the case removed to federal court.
  7. Murray v. Alphabet Inc. (D. Utah): Complaint filed, case in progress, no judicial action so far.
  8. Grybniak v. Google LLC (D.P.R.): Complaint filed, case in progress, no judicial action so far.
  9. Grybniak v. X.AI LLC (D.P.R.): Complaint filed, case in progress, no judicial action so far.

For a case that alleges false and reputation-damaging hallucinations but that doesn't include a defamation claim, see Doe v. OpenAI Found. (Cal. Super. Ct.); there also hasn't been judicial action there.

Eugene Volokh is the Thomas M. Siebel Senior Fellow at the Hoover Institution at Stanford, and the Gary T. Schwartz Distinguished Professor of Law Emeritus and Distinguished Research Professor at UCLA School of Law. Naturally, his posts here (like the opinions of the other bloggers) are his own, and not endorsed by any institution. He is also the co-host of the Free Speech Unmuted podcast.