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SEO Web Design / SEO  / One-star ratings on Google are deemed not defamatory and why that’s a problem

One-star ratings on Google are deemed not defamatory and why that’s a problem

Eric Goldman, Associate Dean for Research and Professor of Law at Santa Clara University School of Law recently wrote[1] about a case in Michigan where a law firm had a 1-star review left that had no text in it. [We also covered it in our daily brief[2] a while back.] The identity of the user is unknown and the law firm claimed that the user posted the wordless one-star review to their Google My Business listing with the intent to cause damage to their reputation or profession and to dissuade potential clients from doing business with them.

“We conclude that, as a matter of law, a one-star wordless review posted on Google Review is an expression of opinion protected by the First Amendment,” the Michigan court stated[3].

The court also said that even if the user was a competitor, it wouldn’t alter their decision: “Regardless of Doe 2’s true identity, this does not alter our conclusion that a one-star wordless review on Google review is an opinion, even if it violates Google’s policy.”

At the time of writing this, I am unable to find this review anywhere on the law firm’s listings for any of their offices so it looks like it was somehow able to be removed.

Recently, I helped on a case at the Google My Business forum that involved a business getting over 30 1-star ratings with no text. They were getting about 2-3 a day and it caused their average rating to tank very quickly. Google said the reviews didn’t violate their guidelines, as they often do with ratings that don’t include text, and refused to remove them. The business owner was devasted and told me that as a result his phone stopped ringing and he had to lay off staff. It’s now been about 6 months since I’ve heard from him and when checking his listing I noticed a recent review indicates that the business location has now closed. 

Example of One Star Reviews in Google

One-star ratings with no text offer little value to customers since they provide absolutely no context to support the rating. They are also the most difficult type of negative review to get Google to remove[4]. Since there is no text, there is often absolutely nothing you can point to that will convince Google that it violates their guidelines. 

Why should we care? It is extremely difficult to get 1-star reviews removed, so it’s critical that local SEOs set reasonable expectations with the small businesses they assist. Having a solid review management strategy in place is crucial to make sure that you are prepared for if and when you have the unfortunate situation that involves dealing with a 1-star review without text. 

Further reading…

Opinions expressed in this article are those of the guest author and not necessarily Search Engine Land. Staff authors are listed here[5].

About The Author

Joy is the owner of the Local Search Forum[6] and Sterling Sky[7] in Canada. She is also the author of The Expert’s Guide to Local SEO[8], which is an advanced training manual for people wanting a detailed look at what it takes to succeed in the Local SEO space. She has been working in the industry since 2006. She is a faculty member at LocalU and enjoys speaking regularly at marketing conferences such as SMX, LocalU, Pubcon and State of Search. You can find her on Twitter or volunteering as a Product Expert[9] on the Google My Business Forum.


  1. ^ recently wrote (
  2. ^ daily brief (
  3. ^ stated (
  4. ^ negative review to get Google to remove (
  5. ^ here (
  6. ^ Local Search Forum (
  7. ^ Sterling Sky (
  8. ^ The Expert’s Guide to Local SEO (
  9. ^ Product Expert (

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