In the ruling published on July 22, Pooler said bitcoins are not "tangible wealth" because of reasons including the fact they "cannot be hidden under a mattress like cash and gold bars."
"This court is not an expert in economics, however, it is very clear, even to someone with limited knowledge in the area, that bitcoin has a long way to go before it is the equivalent of money," she said.
Despite the ruling, bitcoin has been used to buy goods and services from online retailers for some time and more and more retailers are accepting bitcoin payments in stores.
Judge Pooler failed to give bitcoin the credit it deserves, according to Christopher Burniske, analyst and blockchain products lead at financial services firm ARK Investment Management.
"Judge Pooler's commentary around bitcoin not being accepted as a means of exchange by all merchants could be applied to someone trying to use the Kenyan shilling in the U.S. and being denied," he told CNBC in an email.
"Just because the Kenyan shilling is not accepted by all merchants doesn't mean it's not a currency, and the same applies to bitcoin."