By George Lee, Barrister & Solicitor · George Lee Law / 李广田律师事务所
It takes about fifteen seconds to leave a Google review. One star. A few angry sentences typed in a parking lot. Then you tap “Post,” slide the phone into your pocket, and forget about it.
Rosa Deck did something like that. Unhappy with a breast augmentation, she wrote up her experience and put it online — on her own blog and on Google Reviews. She believed every word of it. She thought she was warning other women.
Three years later, a judge of the B.C. Supreme Court ordered her to pay the surgeon $30,000, take the posts down, and never put them back up: Peterson v. Deck, 2021 BCSC 1670.
If you run a business in Richmond or Vancouver, you have probably lain awake over a review that simply was not true. And if you have ever fired off a furious review of your own, you may have assumed the law had nothing to say about it. Both instincts deserve a second look. A Google review is not a diary entry, and it is not a shout into the void. It is a publication — and publications have law attached to them.
The comfortable myths
Most people who land in trouble over a review walk in carrying one of a handful of comfortable beliefs.
The first is “it’s just my opinion.” The second, close behind, is “it’s free speech — I can say what I want.” A third: “as long as I believe it’s true, I’m fine.” And a fourth, popular with anonymous accounts: “they’ll never know it was me.”
Business owners have their own version. The most expensive one is “I’ll just sue and shut them down.” They picture a quick lawyer’s letter, a frightened reviewer, a deleted post. What they often get instead is a counter-application under B.C.’s anti-SLAPP law, their own case thrown out, and a costs order against them.
Each of these beliefs contains a grain of truth, which is exactly what makes them dangerous. Opinion is protected. Free expression is a constitutional value. Truth is a complete defence. And the law does guard genuine public criticism of a business. But every one of those protections comes with conditions — and the gap between what people think the law says and what it actually says is where the lawsuits live.
What the law actually says
So let me set it out plainly.
Online reviews are subject to the law of defamation. Full stop. A review dressed up as harmless commentary can still be defamatory if it is not factually accurate and does not qualify as fair comment. That was the heart of Peterson v. Deck, and it is the settled starting point in this province.
Defamation itself is not hard to describe. Under the framework the Supreme Court of Canada set in Grant v. Torstar Corp., 2009 SCC 61, a statement is defamatory if three things are true: it would tend to lower your reputation in the eyes of an ordinary, reasonable person; it identifies you, by name or in a way readers can work out; and it was communicated to at least one other person. That last point surprises people. You do not need the review to “go viral.” Publication to a single reader is enough — and a public Google review is, by definition, published to the world.
The real action is in the defences, and there are two you need to understand.
Truth — lawyers call it justification — is an absolute defence. If what you wrote is true, you win. But the burden is on you to prove it, and “I genuinely believed it” is not the same as “it happened.” In Peterson, the former patient sincerely felt she had been wronged. The court found her central factual claims about the surgery were not made out. Sincerity did not save her.
Fair comment protects opinion — but only opinion that clears three bars. The comment must be on a matter of public interest; it must be recognizable as opinion rather than a bald assertion of fact; and it must be an opinion a person could honestly hold based on facts that are actually true. This is where most “it’s just my opinion” reviews fall apart. Write “the food made me sick” as a statement of fact, and calling it your “opinion” afterward will not help if it did not happen. In Peterson, the judge found that a reasonable person who knew the real facts could not honestly have expressed the opinions in the posts. Fair comment collapsed.
Then there is anti-SLAPP — the protection people most often misunderstand, in both directions. British Columbia’s Protection of Public Participation Act, SBC 2019, c. 3, lets a defendant ask the court to dismiss a defamation claim early if the expression was on a matter of public interest. It exists to stop powerful parties from using lawsuits to silence legitimate criticism. The framework comes from 1704604 Ontario Ltd. v. Pointes Protection Assn., 2020 SCC 22, and Hansman v. Neufeld, 2023 SCC 14. But — and this is the part both sides miss — the law does not hand reviewers a blank cheque. Even where a review touches the public interest, the case can still proceed if the harm to the plaintiff is serious enough to outweigh society’s interest in protecting that particular speech. That is exactly how Dr. Peterson’s claim survived: the court agreed that a review of a surgeon’s skills was a matter of public interest, then found the harm serious enough to let the action go forward anyway.
The honest summary is this. An opinion, clearly framed as an opinion, resting on facts that are true, about something the public has a real stake in, is very well protected in British Columbia. A false statement of fact, typed as though it were gospel, is not protected at all — no matter how many stars you attach to it.
What the recent cases show
Peterson v. Deck is the case to know, but it is not the whole picture. Line the recent B.C. decisions up side by side and a pattern emerges: the size of the award climbs with the seriousness of the lie and the proof of harm. It helps to read them from the bottom up.
At the very bottom sits a single dollar. In Acumen Law Corporation v. Nguyen, 2018 BCSC 961, a Vancouver lawyer sued a former client who had called her, in a misspelled Google review, the “worstest lawyer.” She won, in the narrow sense — the client never defended, so liability was hers for the taking. But when it came time to assess damages, Madame Justice Murray awarded exactly one dollar, and added that, in her view, the action should never have been brought. Anyone with an online profile invites reviews, the court observed, and no one should expect them all to glow. A reasonable reader would not have thought less of the lawyer for that post in any event — a pointed reminder that “winning” and “being made whole” are not the same thing.
A rung up, but still modest, is Pacific Granite Manufacturing Ltd. v. Lee, 2024 BCSC 1790. A Coquitlam stone-products company sued over a one-star Google review left not even by a customer, but by a man angry that one of the company’s vehicles had struck his car. The court agreed a single line was defamatory — and awarded just $3,000: a thousand dollars to the company and a thousand to each of its two owners. Why so little? Because the company put forward no evidence that the review had actually cost it anything: no lost customers, no lost contracts. A corporation can recover for genuine injury to its business reputation, but it has to prove that injury, not merely assert it.
Higher still is Premier Finance Ltd. v. Ginther, 2022 BCSC 1461 — the case of the lumber business known as Longhouse. A disgruntled customer posted sustained, false reviews accusing the company of fraud and deceit, refused to take them down for years, and admitted that he wanted to harm the business. The court found malice and awarded roughly $90,000. Falsehood, plus persistence, plus ill will is an expensive combination.
At the top of this group is I Buy Beauty LLC v. Dong, 2024 BCSC 815. A YouTuber accused a company of outright crimes — money laundering, human trafficking — before a large audience, over many months. The award was $350,000. The more serious the accusation and the wider the audience, the steeper the price.
Read the ladder from bottom to top and the principle is unmistakable: damages track the seriousness of the falsehood and the proof of harm. A clumsy one-line gripe that changed nothing is worth a dollar. A calculated, malicious campaign of fraud or crime allegations, broadcast to thousands, is worth tens or hundreds of thousands. Where any given review lands depends on what was said, how false it was, how far it travelled, and what it actually cost the person it targeted.
The courts also have teeth beyond money. In Nanaimo (City) v. Propp, 2024 BCSC 2465, where the defendant kept posting after being warned, the court granted not just damages but a permanent injunction — and a mandatory order requiring him to take the statements down. Where a reviewer will not stop, or where a damages award would be hard to collect, an order to remove the content is often the remedy that matters most. And in rare cases the court can reach the platform itself. In Google Inc. v. Equustek Solutions Inc., 2017 SCC 34 — an intellectual-property and trade-secret case rather than a review dispute — the Supreme Court of Canada upheld an order requiring Google to de-index the offending material from its search results worldwide, a remedy that remains exceptional.
The bare star — and the fake reviewer
Two questions come up so often they deserve a direct answer.
First: can a bare one-star rating — just the star, with no words — be defamation? Almost never. Strip away the text and you strip away the one thing defamation needs: a statement of fact that can be proven false. A lone star reads as raw opinion, a mood, a shrug. When a lawyer sued over a wordless one-star rating he suspected a competitor had planted, the court in Gursten v. Doe (Michigan Court of Appeals, 2021) held that a wordless one-star review is opinion as a matter of law — even if the reviewer was a malicious competitor who had never been a client. The star alone says nothing a court can test for truth. That is U.S. law, but the logic — fact versus opinion — is exactly the line our own courts draw.
Second, and far more useful for businesses: what about reviews from people who were never your customers at all? Here the ground shifts hard. Every review carries an unspoken factual claim — I dealt with this business, and here is what happened. If the reviewer was never a customer, that built-in claim is false from the very first word. That is what underpinned the award in Pacific Granite: the one-star reviewer there was no customer at all, but a stranger angry that one of the company’s vehicles had struck his car.
The same issue sits at the centre of a Burnaby case worth watching. Dr. Edward Chin, a pediatric dentist at Smiley Kids Dental, sued over a one-star review that read, “Dr. Chin had horrible customer service and treated our child with 0 care.” When he checked his records, he says, the account that posted it did not appear anywhere as a patient or a parent. In a 2022 ruling, Justice Funt of the B.C. Supreme Court refused to throw the claim out, holding that a reasonable parent searching for a children’s dentist could read the post as a specific and damaging factual charge — not harmless internet noise — and allowed the case to proceed: Smiley Kids Dental v. Huang, 2022 BCSC 1568. (The allegations have not been proven; the case was cleared to go forward, not decided.)
The lesson cuts cleanly. A bare star is the hardest thing in the world to sue over; a worded review from someone who was never your customer is among the easiest, because its central premise is a lie. It is also exactly the kind of review Google itself will often take down on request — its own policy requires reviews to reflect a “genuine experience” — which is usually faster and cheaper than a courtroom.
The twist on the horizon
Here is the development to watch. The Supreme Court of Canada is right now considering Prescott v. Benchwood Builders (SCC File No. 41794), an appeal from the Ontario Court of Appeal’s decision in Benchwood Builders, Inc. v. Prescott, 2025 ONCA 171. Ontario homeowners posted scathing reviews about a renovation contractor; the contractor sued; the homeowners tried to have the suit dismissed under anti-SLAPP legislation. The Court of Appeal held that online consumer reviews are not automatically matters of public interest — a ruling that, if echoed by the Supreme Court of Canada, makes it harder for a reviewer to get a defamation suit thrown out at the early stage.
For readers here, this is not a distant Ontario curiosity. The Attorney General of British Columbia has intervened in the appeal, because the answer will shape how our own Protection of Public Participation Act is applied to every restaurant review, contractor review, and Google star-rating in this province. The appeal was heard on May 15, 2026, and as of this writing the decision is on reserve. It is worth watching closely.
If you are the one writing the review
- Stick to what you can prove. Receipts, photos, emails, dates. Truth is your strongest defence — but only if you can put it in front of a judge.
- Separate fact from opinion, and signal which is which. “In my experience the service was slow and I left frustrated” is opinion. “They overcharge everyone and falsify invoices” is a factual allegation you would have to prove.
- Do not accuse anyone of crimes or fraud unless you can back it up. That is where small disputes turn into large judgments.
- Do not wage a campaign. Repeated posts, escalation after a warning letter, and an obvious personal vendetta are what move a court from sympathy to a damages award — with aggravated damages on top.
If a review is hurting your business
- Do not sue in anger. A reflexive lawsuit over an honest, unflattering review can be dismissed under the anti-SLAPP law with costs against you — and even a win can be a single dollar plus a judicial scolding. Pick your battles, and pick the genuinely false, factual ones.
- Respond first, calmly and in public. A measured reply often does more for your reputation than a deleted review ever would.
- Ask the platform. Google will remove content that breaches its own policies, and that route is faster and cheaper than court.
- Document your harm. Save evidence of lost bookings, cancelled contracts, and customers who mention the review. As the Pacific Granite case shows, harm you cannot prove is harm the court will not fully compensate.
- If the reviewer is anonymous, you are not necessarily stuck. In an appropriate case, a court can order a platform to disclose information that helps identify the author.
- Know the remedies on the table: damages, an order to take the post down and not repost it, an injunction, and — in the right case — de-indexing from search results.
The bottom line
The line between a protected opinion and an actionable lie is narrow, and it is drawn on the specific facts of your situation: the exact words, who read them, what is true, and what harm followed. That is not a line you want to guess at — whether you are about to hit “Post,” or about to send a lawyer’s letter.
At George Lee Law (李广田律师事务所), we advise both reviewers and businesses on defamation, reputation, and online speech — in English, Cantonese, and Mandarin. If a review is keeping you up at night, or you have received a letter about one you wrote, talk to us before you make your next move. The cheapest defamation problem to solve is the one you head off early.
This article is general information about B.C. law, not legal advice, and it does not create a solicitor-client relationship. Several of the cases discussed are recent or still in progress — Prescott v. Benchwood Builders is on reserve at the Supreme Court of Canada, and Smiley Kids Dental v. Huang is an interim ruling in a claim not yet decided — so the law may change. For advice on your situation, consult a lawyer.