Kash Patel, director of the Federal Bureau of Investigation (FBI), throughout a Home Intelligence Committee listening to on worldwide threats in Washington, DC, US, on Thursday, March 19, 2026.
Daniel Heuer | Bloomberg | Getty Photographs
A Houston federal courtroom choose on Tuesday dismissed a lawsuit by FBI Director Kash Patel alleging that former FBI official Frank Figliuzzi defamed him by saying Patel final yr had “been seen at nightclubs excess of he has been on the seventh ground of” the bureau’s headquarters in Washington, D.C.
“The Court docket finds that Figliuzzi’s assertion is rhetorical hyperbole that can’t represent defamation,” U.S. District Court docket Decide George Hanks Jr. wrote in his choice. “Accordingly, Dir. Patel has did not state a declare towards Figliuzzi, and his lawsuit should be dismissed.”
The dismissal got here a day after Patel filed an unrelated $250 million defamation lawsuit in D.C. federal courtroom towards The Atlantic journal over a new article that alleged he has abused alcohol.
Whereas ruling on the important thing query of defamation in Figliuzzi’s favor, the choose denied his request that he be awarded courtroom prices and attorneys’ charges beneath Texas’ anti-SLAPP regulation. SLAPP is an acronym for Strategic Litigation In opposition to Public Participation.
Figluizzi’s lawyer, Marc Fuller, in a press release to CNBC, mentioned, “It is a victory for press freedom and the First Modification.”
“Director Patel’s declare towards Frank was baseless, and we’re happy that the courtroom dismissed it,” Fuller mentioned.
Patel’s attorneys didn’t instantly reply to a request for remark.
Figliuzzi, former assistant director for counterintelligence on the FBI, made his crack about Patel on Could 2, 2025, on the MS Now present “Morning Joe.”
“Yeah, properly, reportedly, he is been seen at nightclubs excess of he has been on the seventh ground of the Hoover constructing,” mentioned Figliuzzi.
Patel sued him in June, accusing Figliuzzi of “fabricating a particular lie” concerning the FBI due to Figliuzzi’s “clear animus” towards him.
As proof of that animus, Patel’s lawsuit referenced scathing statements about him by Figliuzzi, which questioned his competence and claimed that “his report reveals no devotion to the Structure, however blind allegiance to [President Donald] Trump.”
“Since changing into Director of the FBI, Director Patel has not spent a single minute inside a nightclub,” Patel’s swimsuit mentioned.
In his choice Tuesday, Hanks wrote that Figliuzzi’s nightclub jibe, “when taken in context, can not have been perceived by an individual of extraordinary intelligence as stating precise information about Patel.”
“An individual of cheap intelligence and studying wouldn’t have taken his assertion actually: that Dir. Patel has truly spent extra hours bodily in a nightclub than he has spent bodily in his workplace constructing,” Hanks wrote.
“By saying that Patel spent ‘way more’ time at nightclubs than his workplace, Figliuzzi delivered his reply ‘in an exaggerated, provocative and amusing manner,’ using rhetorical hyperbole,” the choose wrote.
