Mm… no. I don’t think so.
I am not a lawyer. This is not legal advice.
A quick reading through an online search shows me that the lawsuit was against pogo, not ingress. And the basis of the complaint was trespassing as encouraged by Niantic, a commercial enterprise. The complainants won an award of $1000 each, (a trivial amount by these standards), legal fees, and some promises from Niantic.
Now… reading between the lines… there is a trespassing complaint, sure. And that was born out in court. However… trespassing is about use without permission. I would argue that a little free library posted on the edge of private property was an open invitation to visit that posting. No trespassing involved because permission was advertised.
Further, if private property were sincerely the boundary, then all waypoints on private property would need to be removed. This has not happened.
More, there’s an argument here that commercial use, (arguable in this case), of someone else’s property requires permission, perhaps a license, perhaps including a royalty fee. This sort of license would apply to municipal parks as well. In most parks, you can’t just set up a hot dog stand. You need a license to do that. You need a license to use community property for commercial purposes. So the restriction of waypoints to other-than-private property is an artificial limit without basis.
All property is owned by someone. If there’s an argument about permission to use for commercial purposes then that argument applies to all property, not just private property.
Finally, the orders resulting from the suit have since expired. They are not longer in force.
So, no. I don’t buy that the private property restriction was the result of a court suit. These are totally different things.