A US federal judge in Nevada on Thursday dismissed a defamation lawsuit brought by FBI Director Kash Patel and his nonprofit foundation against a California blogger on July 25.

Chief US District Judge Andrew P. Gordon of the District of Nevada granted blogger Jim Stewartson’s motion to dismiss under Federal Rule of Civil Procedure 12(b)(2) for a lack of personal jurisdiction. He also vacated the $250,000 default judgment entered in Patel’s favor last year as void under Rule 60(b).(4).

Gordon stressed the limits of his decision stating that it does not resolve whether Stewartson’s statements—which included calling Patel a “Kremlin asset” and “guilty of sedition”—were true, false, or protected opinion. It holds only that Stewartson lacked the minimum contacts with Nevada required for the court to hear the case. Gordon applied the “effects test” from the US Supreme Court’s Calder v. Jones, as well as the Ninth Circuit’s minimum-contacts framework. He found that Stewartson, posting from California, had not expressly aimed his conduct at Nevada. The blogger’s statements, the judge wrote, were directed at “the American body politic writ large” and not towards a Nevada audience. Stewartson tagging Patel, a Nevada resident, online did not create the necessary connection. He distinguished Calder, where California had been the “focal point” of both the story and the harm.

Patel, a longtime ally of President Donald Trump, was confirmed to lead the FBI in 2025. He filed the suit back in June 2023, before his appointment. The complaint sought $10 million on claims of defamation, injurious falsehood, and business disparagement over a series of online posts. These included statements that Patel had “attempted to overthrow the government,” “planned” the January 6 Capitol attack, and was a “blatantly incompetent chud”, which refers to a pejorative for figures on the political right.

Stewartson did not initially respond, and Gordon entered a default judgment on August 5, 2025. He awarded Patel $200,000 and the Kash Foundation $50,000—far less than the $10 million sought. In September, Stewartson moved to vacate the judgment and dismiss the case, arguing that he was never properly served, that Nevada lacked jurisdiction, and that the claims were barred by the First Amendment.

Although he ruled for Stewartson, Gordon criticized the blogger’s conduct. He wrote that Stewartson appeared to know about the suit, may have tried to avoid service, and had “wasted the plaintiffs and the court’s time.” The judge said he would have required Stewartson to pay Patel’s attorney’s fees had he possessed the discretion to do so, but concluded that a judgment void for a lack of jurisdiction left him with no such power. Stewartson celebrated the ruling on X, noting that Gordon had cited some of his cruder language in a footnote.

The dismissal comes as Patel pursues a separate $250 million defamation suit against The Atlantic over an April article describing his alleged drinking. The magazine has moved to dismiss the case. The New York Times reported in June that Patel has filed six defamation suits over the last seven years.