"The judge said that Frank Figliuzzi's statement, "when taken in context, cannot have been perceived by a person of ordinary intelligence as stating actual facts about Patel.""

"A federal judge in Texas has tossed a defamation suit brought by FBI Director Kash Patel against former FBI assistant director-turned-MSNBC contributor Frank Figliuzzi.

Patel had sued Figliuzzi over comments he made on "Morning Joe" about the FBI director’s evening activities.

"Yeah, well, reportedly, he’s been visible at nightclubs far more than he has been on the seventh floor of the Hoover building," Figliuzzi said on the show last year."

Tom Winter reports for NBC News April 22, 2026. [2]