I suspect that the outcome of this where Google devices have to have volume controlled individually isn't due to a patent on that specific functionality, but due to something with the inter-speaker communication system that Sonos pioneered (multiple wireless speakers playing sound in sync with each other, with no audible delay). Google will have had to change how they have speakers talk to each other and the side effect is the lack of group volume control.
A patent on "speaker group volume control" I agree would be silly, but a parent on a wireless control system and protocol for multiple speakers that can be grouped together is far less so.