FBI Director Kash Patel‘s defamation lawsuit against news analyst Frank Figliuzzi has reportedly been dismissed by a Houston federal court. The legal setback comes shortly after the FBI Director filed another lawsuit against The Atlantic on Monday.
Judge dismisses Kash Patel’s new defamation lawsuit
A Houston federal court judge has dismissed a defamation lawsuit filed by Kash Patel against former FBI Assistant Director for Counterintelligence Frank Figliuzzi, who now serves as an analyst for NBC News and MSNBC. The FBI director had alleged that Figliuzzi defamed him after saying that he frequents nightclubs in Washington, D.C.
“The Court finds that Figliuzzi’s statement is rhetorical hyperbole that cannot constitute defamation,” U.S. District Court Judge George Hanks Jr. wrote. “Accordingly, Dir. Patel has failed to state a claim against Figliuzzi, and his lawsuit must be dismissed.”
Patel filed the lawsuit in June 2025 after Figliuzzi took a dig at him during an appearance on MSNBC’s Morning Joe, the previous month. “Well, reportedly, he’s been visible at nightclubs far more than he has been on the seventh floor of the Hoover building,” the former FBI official stated.
Judge Hank, in his Tuesday dismissal of Patel’s lawsuit, wrote, “A person of reasonable intelligence and learning would not have taken his statement literally: that Dir. Patel has actually spent more hours physically in a nightclub than he has spent physically in his office building.” The document further explained, “By saying that Patel spent ‘far more’ time at nightclubs than his office, Figliuzzi delivered his answer ‘in an exaggerated, provocative and amusing way,’ employing rhetorical hyperbole.”
The dismissal comes just a day after Kash Patel filed another defamation lawsuit on April 20, this time against The Atlantic. The FBI Director denied all claims made by a recent article from the magazine by writer Sarah Fitzpatrick about his alleged drinking on the job, calling it a “sweeping, malicious, and defamatory hit piece.”
Shortly after, The Atlantic issued a statement, saying, “We will vigorously defend The Atlantic and our journalists against this meritless lawsuit.”
Originally reported by Namrata Ghosh on Mandatory.
