Kash Patel defamation lawsuit against Figliuzzi dismissed

Federal Bureau of Investigation (FBI) director Kash Patel during a House Intelligence Committee hearing on worldwide threats on Thursday, March 19, 2026 in Washington, DC, USA.
Daniel Heuer | Bloomberg | Getty Images
A federal judge in Houston on Tuesday dismissed one lawsuit. case FBI Director Kash Patel claimed he was slandered by former FBI official Frank Figliuzzi, who said Patel was “more visible at nightclubs than on the seventh floor” of the bureau’s headquarters in Washington, D.C.
The lawsuit is unrelated to another defamation lawsuit Patel filed against The Atlantic magazine on Monday. article He claimed he was drinking alcohol. This civil complaint, filed in D.C. federal court, seeks $250 million in damages.
Figliuzzi, the former deputy director of counterintelligence at the FBI, commented about Patel on the MS Now show “Morning Joe.”
“The court found that Figliuzzi’s statement was a rhetorical exaggeration and
In the decision, U.S. District Court Judge George Hanks Jr. wrote that it “constitutes libel.”
“Accordingly, Principal Patel has not made a claim against Figliuzzi and his case must be dismissed.”
CNBC has requested comment from attorneys for Patel and Figliuzzi.
Hanks wrote in his ruling that Figliuzzi’s sarcasm about Patel “when taken in context, could not be perceived by a person of ordinary intelligence as expressing actual facts about Patel.”
“As alleged, Figliuzzi’s statement about Patel — again in response to a question about Patel’s diminished visibility as FBI Director — was that ‘he was much more visible in nightclubs than he was on the seventh floor of the Hoover building,'” the judge wrote.
“A person of reasonable intelligence and education would not take his statement literally: Director Patel spent more hours physically in a nightclub than he physically spent in his office building,” Hanks wrote.
“Figliuzzi responded using rhetorical hyperbole in an ‘exaggerated, provocative and entertaining manner,’ saying Patel spent ‘much more time’ in nightclubs than in his office.”
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