A federal judge has dismissed arguments from former FBI agent Peter Strzok that his 2018 firing violated his constitutional rights.

Strzok, who played a leading role in the bureau’s Crossfire Hurricane investigation into President Donald Trump’s 2016 campaign and alleged ties to Russia, was terminated after sending anti-Trump text messages on his FBI-issued phone.

The ruling, issued by U.S. District Judge Amy Berman Jackson, concluded that Strzok’s First Amendment and Fifth Amendment claims could not stand.

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Jackson, an appointee of former President Barack Obama, wrote that the FBI acted within its authority when it dismissed Strzok due to concerns over bias and disruption to bureau operations.

“At this point, only two issues remain to be resolved: did plaintiff’s termination violate the First Amendment, and did his termination violate the Fifth Amendment guarantee against the deprivation of property without due process of law?” Jackson stated in her order.

On the First Amendment question, the court ruled that Strzok’s communications created a clear conflict with the FBI’s interest in maintaining neutrality and credibility during ongoing investigations.

“The plaintiff’s interest in expressing his 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 of those very people, and in protecting against the disruption of its law enforcement operations under then-Director Wray’s leadership,” the order read.

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The court also rejected Strzok’s claim that his termination violated due process protections.

“As to Count Two, the due process claim is predicated on a misrepresentation of the facts and distortion of the chronology,” Jackson wrote.

She added that Strzok had no contractual right to continued employment that would establish a property interest in his position.

“Once one gets past the rhetoric and considers the undisputed factual record, it becomes clear that there is no evidence to support a finding that plaintiff entered into a contract … that gave him a property interest in his tenure before the Deputy Director exercised his authority to terminate him, or that plaintiff lacked notice and an opportunity to be heard before his fate was decided,” the court document stated.

The decision comes as part of a broader case that has drawn national attention since Strzok’s dismissal.

Strzok, who exchanged private messages critical of then-President Trump with former FBI attorney Lisa Page, was removed from the Russia investigation in 2017 after the texts became public.

His subsequent firing in 2018 was ordered under FBI Director Christopher Wray’s leadership.

While much of the court’s Memorandum Opinion remains sealed, Judge Jackson directed that the full opinion be unsealed unless the parties demonstrate specific reasons to keep portions confidential.

“The full Memorandum Opinion has been docketed under seal,” Jackson wrote, instructing that “nothing in the Memorandum Opinion needs to remain sealed, and therefore, the parties must inform the Court by September 30, 2025 of whether they have any objection to the Court’s unsealing the Memorandum Opinion in its entirety, and if so, specifying what portions they believe should remain under seal and why.”

The ruling reinforces the FBI’s authority to discipline agents whose conduct raises concerns about bias or undermines public trust, particularly during politically sensitive investigations.

The next step will depend on whether Strzok’s legal team challenges the court’s findings or pursues an appeal.

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