Judge dismisses Kash Patel’s defamation suit over claim he frequents ‘nightclubs’

A federal judge in Houston on Tuesday dismissed FBI Director Kash Patel’s 2025 lawsuit alleging that he was defamed by former FBI official Frank Figliuzzi, who said Patel was more likely to be seen in nightclubs than on the seventh floor of the bureau’s headquarters in Washington, DC.

The lawsuit is not related to another defamation suit that Patel filed on Monday against The Atlantic magazine Article It is alleged that he has misused alcohol. That civil complaint, filed in D.C. federal court, seeks $250 million in damages.

Figliuzzi, a former assistant director of counterintelligence at the FBI, had made comments about Patel on the MS Now show “Morning Joe.”

“The Court finds that Figliuzzi’s statement is a rhetorical exaggeration that cannot be
This constitutes defamation,” U.S. District Court Judge George Hanks Jr. wrote in the decision.

“Accordingly, Director Patel has failed to state a claim against Figliuzzi, and his lawsuit should be dismissed.”

“The Court found that Figluzzi’s statement, when taken in context, could not have
It was considered by a person of common sense to be telling the real facts about Patel. As alleged, Figliuzzi’s statement about Patel – again, given in response to a question about Patel’s low visibility as FBI director – led the judge to write, ‘He is far more visible in nightclubs than on the seventh floor of the Hoover Building.’

Hanks wrote, “A person of reasonable intelligence and scholarship would not have taken his statement literally: Dir. Patel has actually spent more hours physically in a nightclub than he has physically spent in his office building.”

“By saying that Patel spent ‘far more’ time in nightclubs than in his office, Figliuzzi delivered his answer ‘in an exaggerated, provocative and amusing manner,’ using rhetorical hyperbole.”

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