The relevant part of the doctrine is: >The fourth factor measures the effect that the allegedly infringing use has had on the copyright owner's ability to exploit his original work. The court not only investigates whether the defendant's specific use of the work has significantly harmed the copyright owner's market, but also whether such uses in general, if widespread, would harm the potential market of the original. The burden of proof here rests on the copyright owner, who must demonstrate the impact of the infringement on commercial use of the work. https://en.wikipedia.org/wiki/Fair_use

Whether a website is scummy or not does not come into play. And frankly the stuff I'm seeing showing up in snippets in google search are very much wikipedia-type content (often exactly wikipedia-type content). And we're not talking snippets that provide context on the search result to enable determining whether this is the content that one is looking for, we're talking significant pieces of the content, often reformatted and presented in such a way that not clicking on the site is precisely the objective of the presentation.