Obama-Appointed Judge Tosses Kash Patel’s Defamation Suit Against Ex-FBI Official – Rules the Claim Patel Spent More Time in Nightclubs Is Just “Rhetorical Hyperbole”

A federal judge has thrown out Kash Patel’s defamation lawsuit against disgraced former FBI official and MSNBC talking head Frank Figliuzzi.

In a sharply worded ruling, U.S. District Judge George C. Hanks Jr., appointed by Barack Obama, dismissed the case outright, concluding that Figliuzzi’s viral claim, that Patel spent more time in nightclubs than at FBI headquarters, was not a statement of fact, but protected speech.

In June 2025, FBI Director Kash Patel filed a defamation lawsuit in Texas against MSNBC’s resident deep state mouthpiece, Frank Figliuzzi, accusing him of fabricating a vicious lie designed to smear Patel’s reputation and sabotage his leadership at the Bureau.

Figliuzzi, a disgraced former FBI official-turned-leftist propagandist, claimed on live television that Patel had “been visible at nightclubs far more than he has been on the seventh floor of the Hoover Building,” the New York Post reported.

Figliuzzi continued, “There are reports that daily briefings to him have been changed from every day to maybe twice weekly. So this is both a blessing and a curse, because if he’s really trying to run things without any experience level, things could be bad.”

WATCH:

FBI Director Kash Patel has sued Frank Figluzzi for fabricating a lie after Figluzzi claimed on MSNBC that Patel spent more time at nightclubs than at the Hoover Building.

Here is the segment where Figluzzi made the claim: pic.twitter.com/oGFaUSR4BX

— Trending Politics (@tpbreaking) June 11, 2025

According to Patel’s legal team, that claim is not only false—it was knowingly made up out of thin air.

“Defendant knew that this was a lie when he said it,” the lawsuit reads. “Since becoming Director of the FBI, Director Patel has not spent a single minute inside of a nightclub.”

The complaint further blasts Figliuzzi’s pathetic attempt to shield himself with the classic fake news escape hatch—saying “reportedly”—when there was never a single report, source, or shred of evidence.

Patel’s attorneys made it clear: “Defendant made up the story out of whole cloth, and by using the word ‘reportedly,’ attempts to distance himself from what is a maliciously false and defamatory statement.”

And now an Obama-appointed federal judge has waved it all away with a wink and a nod.

Judge Hanks made it clear that the statement, when viewed in context, was exaggerated commentary, not a factual allegation.

The ruling emphasized that a “person of ordinary intelligence” would not seriously believe that the FBI Director was literally spending more time partying than running the bureau.

The judge determined that:

• A “reasonable person” would not interpret the nightclub comment as a factual claim
• The statement was an “exaggerated, provocative and amusing” jab
• Therefore, it falls under protected speech as rhetorical hyperbole—not defamation

JUST IN: A federal judge has tossed a defamation lawsuit Kash Patel brought against former FBI official / pundit Frank Figliuzzi.

Figliuzzi’s claim that Patel spent more time in nightclubs than at FBI HQ was “rhetorical hyperbole,” the judge rules. https://t.co/FObW9MLRVq pic.twitter.com/dZ8FUTuXdl

— Kyle Cheney (@kyledcheney) April 21, 2026