Federal judge dismisses Strzok lawsuit over FBI firing tied to anti-Trump texts
U.S. District Judge Amy Berman Jackson ruled that Peter Strzok's termination did not violate First or Fifth Amendment rights, citing the FBI's interest in avoiding bias and protecting ongoing investigations.
A federal judge in the District of Columbia has dismissed former FBI agent Peter Strzok's lawsuit challenging his termination, ruling that his firing over anti-Trump text messages did not violate the Constitution. Strzok, who helped lead the FBI's Crossfire Hurricane investigation into Donald Trump’s 2016 campaign and Russia inquiry, had argued that his First and Fifth Amendment rights were violated by the agency's decision.
In a memorandum opinion, U.S. District Judge Amy Berman Jackson said Strzok's interest in expressing opinions about political candidates on his FBI phone at that time "was outweighed by the FBI’s interest in avoiding the appearance of bias in its ongoing investigations" and in protecting operations under then-Director Christopher Wray. The court described the balance as essential to maintaining public trust in the bureau's work and preventing disruption of investigations.
As to Count Two, the due‑process claim is predicated on a misrepresentation of the facts and distortion of the chronology. The memorandum notes that, once the record is examined, there is no evidence to support a finding that the plaintiff entered into a contract that gave him a property interest in tenure before the Deputy Director exercised his authority to terminate him, or that he lacked notice and an opportunity to be heard before his fate was decided.
The Memorandum Opinion has been docketed under seal, and the court said that nothing in the document necessarily must remain sealed. The parties were ordered to inform the Court by September 30, 2025 of any objections to unsealing the opinion in its entirety and to specify portions that should remain under seal and why.
Strzok, who helped lead the FBI's Crossfire Hurricane probe into the 2016 presidential election and Russia inquiry, was terminated during Donald Trump’s first term. His dismissal has been a focal point in broader debates about agency discipline and transparency from the FBI during the Trump era.
The decision comes as the Department of Justice has addressed concerns about the release of anti-Trump texts and related documents, a matter that has drawn scrutiny from lawmakers and oversight committees as officials weigh public access against privacy and national security considerations. This ruling marks a concrete legal development in that ongoing discourse, even as portions of the opinion remain sealed for now.
The opinion also drew attention to how courts balance individual speech rights with the government’s duty to conduct investigations without appearing biased, a distinction that may influence similar lawsuits by current or former federal employees seeking to challenge disciplinary actions on constitutional grounds.
Ultimately, the ruling underscores the tension between personal political speech on government devices and the FBI’s mission to operate in a nonpartisan manner, a factor the court said is central to maintaining the integrity of federal investigations.