https://ieeexplore.ieee.org/document/5089308, from RCIS 2009 (Beel and Gipp) noted that "Google Scholar seems to be more suitable for searching standard literature than for gems or articles by authors advancing a view different from the mainstream."
Unrelated, but interesting: scraping Google Scholar is remarkably annoying if you want to actually use the data. The easiest way (in my experience) seems to be regex hacking on the BibTeX files, but this seems truly broken.