Kash Patel, director of the Federal Bureau of Investigation (FBI), during a House Intelligence Committee hearing on worldwide threats in Washington, DC, US, on Thursday, March 19, 2026.
Daniel Heuer | Bloomberg | Getty Images
A federal judge in Houston on Tuesday dismissed a 2025 lawsuit by FBI Director Kash Patel that alleged he was defamed by former FBI official Frank Figliuizzi, who had said Patel has “been visible at nightclubs far more than he has been on the seventh floor of the Hoover building.”
The lawsuit is not related to the new defamation lawsuit that Patel filed Monday against The Atlantic magazine over an article that alleged he has abused alcohol.
“The Court finds that Figliuzzi’s statement is rhetorical hyperbole that cannot
constitute defamation,” U.S. District Court Judge George Hanks Jr. wrote in the decision.
“Accordingly, Dir. Patel has failed to state a claim against Figliuzzi, and his lawsuit must be dismissed.”
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