Strzok loses long-running lawsuit over firing tied to anti-Trump texts

A federal judge on Tuesday dismissed Peter Strzok's lawsuit alleging he was illegally fired for anti-Trump text messages while he helped oversee the FBI's Russia investigation. U.S. District Judge Amy Berman Jackson ruled that Strzok failed to show his firing violated his First Amendment rights and that there was no genuine dispute of material fact that would require a trial. The decision means the case cannot proceed, though Jackson did not rule on whether the firing was appropriate.

Strzok, who served in the FBI for more than two decades, was dismissed in August 2018 after emails and text messages surfaced showing a clear anti-Trump bias. He contended that his firing was retaliatory and did not reflect his on-the-job performance. The judge noted that the court’s summary opinion left open the possibility that the FBI could have pursued a demotion instead of termination in some circumstances, but the ruling found no triable factual issue to support Strzok's claim of a protected First Amendment violation. The full ruling is under seal, but the public summary indicates the court rejected Strzok's argument that he had a standing deal with the FBI that would protect him from firing.

In the ruling, Jackson praised Strzok as a highly regarded counterintelligence professional but stressed that the absence of a triable dispute about material facts precluded relief on constitutional grounds. The judge also left undetermined whether the FBI's actions were appropriate in context, noting the decision addresses only the First Amendment claim raised in the lawsuit. Strzok has the option to appeal to the U.S. Court of Appeals for the D.C. Circuit.

Strzok’s firing occurred amid revelations of text messages that suggested a personal bias against Donald Trump, including rhetoric about efforts to prevent Trump from winning the presidency. The proceedings are linked to broader inquiries within the FBI leadership and to documents later examined by the inspector general and Congress. Strzok has repeatedly denied that his personal views influenced investigative work, and the inspector general’s review found no evidence that bias altered the Russia probe’s outcome.

This litigation is only one aspect of a broader set of disputes arising from the texts and disclosures during and after the 2016 campaign. Lisa Page, Strzok’s FBI colleague with whom he exchanged many messages, pursued a separate Privacy Act suit. Page was awarded an $800,000 payout by the Justice Department in a settlement reached last year, while Strzok was awarded about $1.2 million in connection with his termination; those figures were not tied to the Strzok firing lawsuit. The Strzok case itself centers on constitutional protections and the manner in which the FBI decides to discipline personnel, rather than on the broader political fallout from the Russia investigation.