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Kash Patel, director of the Federal Bureau of Investigation (FBI), all over a Home Intelligence Committee listening to on worldwide threats in Washington, DC, US, on Thursday, March 19, 2026.

Daniel Heuer | Bloomberg | Getty Photography

A Houston federal court docket mediate on Tuesday pushed apart a lawsuit by FBI Director Kash Patel alleging that extinct FBI respectable Frank Figliuzzi defamed him by pronouncing Patel final 300 and sixty five days had “been visible at nightclubs far more than he has been on the seventh floor of” the bureau’s headquarters in Washington, D.C.

“The Court finds that Figliuzzi’s statement is rhetorical hyperbole that cannot constitute defamation,” U.S. District Court docket Resolve George Hanks Jr. wrote in his decision. “Accordingly, Dir. Patel has failed to state a claim against Figliuzzi, and his lawsuit must be dismissed.”

The dismissal came a day after Patel filed an unrelated $250 million defamation lawsuit in D.C. federal court docket in opposition to The Atlantic journal over a recent article that alleged he has abused alcohol.

Whereas ruling on the predominant ask of defamation in Figliuzzi’s want, the mediate denied his quiz that he be awarded court docket expenses and attorneys’ expenses under Texas’ anti-SLAPP law. SLAPP is an acronym for Strategic Litigation In opposition to Public Participation.

Figliuzzi’s lawyer, Marc Fuller, in a statement to CNBC, talked about, “This is a victory for press freedom and the First Amendment.”

“Director Patel’s claim against Frank was baseless, and we are pleased that the court dismissed it,” Fuller talked about.

Patel’s attorneys failed to immediately answer to a quiz for comment.

Figliuzzi, extinct assistant director for counterintelligence at the FBI, made his crack about Patel on Can also fair 2, 2025, on the MS NOW characterize “Morning Joe.”

“Yeah, well, reportedly, he’s been visible at nightclubs far more than he has been on the seventh floor of the Hoover building,” talked about Figliuzzi.

Patel sued him in June, accusing Figliuzzi of “fabricating a specific lie” in regards to the FBI director thanks to Figliuzzi’s “clear animus” in direction of him.

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As evidence of that animus, Patel’s lawsuit referenced scathing statements about him by Figliuzzi, which wondered his competence and claimed that “his record shows no devotion to the Constitution, but blind allegiance to [President Donald] Trump.”

“Since becoming Director of the FBI, Director Patel has not spent a single minute inside of a nightclub,” Patel’s swimsuit talked about.

In his decision Tuesday, Hanks wrote that Figliuzzi’s nightclub gibe, “when taken in context, cannot have been perceived by a person of ordinary intelligence as stating actual facts about Patel.”

“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,” Hanks wrote.

“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 mediate wrote.