Federal Bureau of Investigation (FBI) Director Kash Patel attends a House Intelligence Committee hearing on global threats on Thursday, March 19, 2026 in Washington, DC, USA.
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A federal judge in Houston on Tuesday dismissed a lawsuit accusing FBI Director Kash Patel of defamation by former FBI official Frank Figliwizzi in 2025. Figliwizzi said Patel “became more visible in nightclubs than on the seventh floor of FBI headquarters in Washington, D.C.”
The lawsuit is unrelated to a separate defamation lawsuit Patel filed Monday against The Atlantic over an article alleging alcohol abuse.
Figliuzzi, the FBI’s former deputy director for counterintelligence, made the comments about Patel on MS Now’s “Morning Joe.”
“The court found that Figliuzzi’s statement was a rhetorical exaggeration that was impossible.
This constitutes defamation,” U.S. District Court Judge George Hanks Jr. said in the ruling.
“Therefore, Coach Patel has not made any allegations against Figliuzzi and his case should be dismissed.”
:The court found that Figliuzzi’s statements were implausible given the context.
It would be perceived by a person of ordinary intelligence as stating actual facts about Patel. As alleged, Figliuzzi’s statement about Patel, also made in response to a question about Patel’s declining profile as FBI director, was that “he was now more often seen in nightclubs than on the seventh floor of the Hoover Building,” the judge wrote.
“No reasonably intelligent and learned person would take his statement literally: that Secretary Patel spent more time physically in a nightclub than he physically spent in an office building,” Hanks wrote.
Stating that Mr. Patel spent “far more” time in nightclubs than in the office, Mr. Figliuzzi responded using rhetorical hyperbole “in an exaggerated, provocative and amusing manner.”
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