A Texas court has dismissed a defamation lawsuit filed by Kash Patel, a former Trump administration official, against MSNBC national security analyst Frank Figliuzzi. The lawsuit stemmed from comments Figliuzzi made on air in 2022, suggesting Patel spent more time in nightclubs than at the office while serving in government.
According to court documents, the U.S. District Court for the Northern District of Texas granted Figliuzzi's motion to dismiss the case on April 17, 2026. The judge ruled that Figliuzzi's statements were protected opinion under the First Amendment and that Patel, as a public figure, failed to prove the comments were made with "actual malice."
Kash Patel held several national security roles, including chief of staff to the acting Secretary of Defense, and was a prominent figure during investigations into the January 6th Capitol attack. Frank Figliuzzi is a former assistant director for counterintelligence at the FBI and now a frequent media commentator.
The dismissal marks the end of this legal attempt by Patel, who has been involved in other litigation and political activities since leaving government service. Legal experts note the ruling reinforces the high bar public figures must clear to succeed in defamation claims against critics.
