I think it called for at least a throwaway line: "I cite the case of Data vs Maddox, in which a machine intelligence was granted the rights of a sentient being." It seems like the first thing a lawyer who researched the issue would come across to me.
Yeah, it did seem like the ruling was a 'Sidestep the issue' ruling, and a cowardly attempt not to be the judge to gave holograms rights.
I wonder if this is just a case if they mentioned Maddox of Louvois(might have misspelled that) they'd have to pay royalties. Though Voyager was never shy about after referencing TNG.
Also... why didn't Zimmerman testify in that instead of Barclay by proxy? Was the actor who played him not available?