BOBULINSKI v. HUTCHINSON

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
ANTHONY BOBULINSKI,
Plaintiff,
v.
CASSIDY HUTCHINSON,
Defendant.
Civil Action No. 25-771 (EGS)
MEMORANDUM OPINION
Plaintiff Anthony Bobulinski (“Mr. Bobulinski”) brings this
action against Defendant Cassidy Hutchinson (“Ms. Hutchinson”)
in a three-count Complaint alleging Defamation, Defamation by
Implication, and False Light Invasion of Privacy arising out
statements in Ms. Hutchinson’s book entitled “Enough.” See
generally Compl., ECF No. 1.1
Pending before the Court is Ms. Hutchinson’s Motion to
Dismiss, ECF No. 52. Upon careful consideration of the Motion,
Opposition, Reply, the applicable law, and for the reasons
explained below, the Court GRANTS the Motion to Dismiss.
1 When citing electronic filings throughout this opinion, the
Court cites to the ECF header page number, not the original page
number of the filed document.
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I. 	Background
A. Factual
The following facts are taken from the allegations in the
Complaint, which the Court assumes are true for the purposes of
deciding this motion and construes in Mr. Bobulinski’s favor.
See Baird v. Gotbaum, 792 F.3d 166, 169 n.2 (D.C. Cir. 2015).
Mr. Bobulinski is a “decorated Navy veteran and successful
businessman.” Am. Compl., ECF No. 20 ¶ 10. After his military
service, Mr. Bobulinski joined Hunter Biden in or around 2017 as
a business partner serving as CEO of SinoHawk Holdings, “a
company designed to find investments in the United States.” Id.
¶ 13. Mr. Bobulinski subsequently “confirmed to the United
States Senate the veracity of [] emails [indicating] that Joe
Biden was involved with his son’s business dealings with foreign
nations, and that the Biden family accepted money from foreign
nations.” Id. ¶ 18.
“On November 1, 2020, Mr. Bobulinski attended one of
President Trump[’s] campaign rallies in Rome, Georgia, and
briefly met with Mark Meadows, President Trump’s Chief of Staff,
during the rally.” Id. ¶ 23. Ms. Hutchinson served as principal
assistant to Mr. Meadows, id. ¶ 24; and in September 2023
published a book entitled, Enough, id. ¶ 42. In the book, Ms.
Hutchinson describes the meeting between Mr. Bobulinski and Mr.
Meadows at the campaign rally as follows:
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In 	the 	shadows 	of 	the 	bleachers, 	I 	observed
Mark and Tony Bobulinski’s interaction through
a 	gap 	in 	the 	vehicles. 	When 	they 	said 	their
goodbyes, 	I 	saw 	Mark 	hand 	Tony 	what 	appeared
to 	be 	a 	folded 	sheet 	of 	paper 	or 	a 	small
envelope.
Id. ¶ 44 (quoting C ASSIDY H UTCHINSON, ENOUGH (2023) at 221). Mr.
Bobulinski alleges that Ms. Cassidy’s statement is false: “at no
point did Mr. Meadows hand Mr. Bobulinski any sheet of paper or
envelope.” Id. ¶ 45.
Mr. Bobulinski alleges that Ms. Hutchinson “made this
accusation to imply that Mr. Bobulinski was involved with some
sort of shady business dealing with Mr. Meadows,” and that her
commentary and juxtaposition of other facts creates a
“defamatory implication.” Id. ¶¶ 46, 47. In support, he quotes
the following text:
I didn’t know much about Tony Bobulinski, just
that 	he 	was 	a 	former 	business 	associate 	of
Hunter 	Biden’s 	and 	had 	something 	to 	do 	with
the laptop controversy. Trump had brought him
as 	a 	guest 	to 	the 	presidential 	debate 	in
Nashville on October 22. I wasn’t tracking the
story closely enough to know more. But as Mark
approached, I had a weird feeling that we were
in 	danger. 	I 	couldn’t 	explain 	it, 	but 	the
feeling was real. “Mark shouldn’t do this,” I
said to Tony [sic]. “He’s being set up.” Tony
shrugged. “Don’t overthink things. It’s not a
big 	deal. 	Chief 	knows 	what 	he’s 	doing.
Bobulinski 	came 	with 	us 	to 	Nashville,
remember? 	Don’t 	worry, 	kid.” 	He 	patted 	my
shoulder 	and 	walked 	away 	as 	Mark 	approached
me.
“You’re 	not 	meeting 	Tony 	Bobulinski 	here,
Mark. We can send someone from the campaign.”
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I 	heard 	my 	voice 	whine 	with 	childlike
desperation. “Please, Mark. This isn’t a good
idea. 	Just 	trust 	me.” 	Mark 	looked 	at 	his
Secret 	Service 	agent, 	then 	back 	at 	me. 	“Just
go 	find 	him, 	and 	work 	with 	Secret 	Service 	to
find a hidden spot. Come get me once you have
him there.”
. . .
“This 	is 	really 	stupid 	of 	you, 	Mark. 	I 	don’t
know what’s going on, but it’s really stupid,”
I 	said. 	He 	didn’t 	have 	time 	to 	respond 	as 	I
ushered him into the makeshift area, away from
cameras, 	as 	requested, 	but 	not 	from 	watchful
Secret Service eyes.
. . .
I 	had 	done 	what 	they 	had 	asked 	of 	me, 	not
questioning 	it, 	but 	now 	I 	started 	to 	put
together 	all 	the 	moments 	like 	this 	one 	that
didn’t 	add 	up. 	I 	could 	not 	shake 	the 	feeling
that 	I 	had 	been 	entangled 	in 	something 	far
more 	complex 	and 	secretive 	than 	I 	had
initially realized.
Id. ¶ 49 (quoting C ASSIDY H UTCHINSON, ENOUGH (2023) at 218-222).
Mr. Bobulinski does not dispute that he and Mr. Meadows met
that day, but states that while it was “an innocent meeting,”
Ms. Hutchinson’s description “provided the false implication”
that the two “were involved in some sort of nefarious dealings,
and painted Mr. Bobulinski in a false and negative light.” Id. ¶
50. He states that the meeting between himself and Mr. Meadows
was “simply an exchange of pleasantries” and that Mr. Meadows
wanted to check on “the well-being of Mr. Bobulinski and his
family” after being thrust into the public spotlight “for simply
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telling his firsthand account of the truth about the Biden
family.” Id. ¶¶ 51, 52, 54.
B. Procedural
On March 4, 2024, Mr. Bobulinski filed suit against Ms.
Hutchinson in the Northern District of Georgia, see Compl., ECF
No. 1; and Ms. Hutchinson filed a Motion to Dismiss, see Mot. to
Dismiss, ECF No. 17. Mr. Bobulinski then filed a First Amended
Complaint (“FAC”) asserting state law claims for defamation,
defamation by implication, and false light–invasion of privacy.
See generally Am. Compl., ECF No. 20. Ms. Hutchinson moved to
dismiss the FAC for lack of personal jurisdiction and failure to
state a claim. See generally Mot. to Dismiss, ECF No. 25. The
court in the Northern District of Georgia held a hearing on the
Motion to Dismiss, and the court requested briefing on whether
the case should be transferred for lack of personal jurisdiction
over Ms. Hutchinson in lieu of dismissal. Mot. to Dismiss, ECF
No. 52 at 9. Mr. Bobulinski then filed a Motion to Transfer, and
Ms. Hutchinson objected to the transfer in lieu of dismissal.
Id.
On March 17, 2025, the court in the Northern District of
Georgia granted in part Ms. Hutchinson’s Motion to Dismiss and
transferred the case. Order, ECF No. 41. The case was assigned
to this Court in March 2025. On March 25, 2025, the parties
filed a joint motion for leave to file supplemental briefing and
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set a briefing schedule. Mot. for Leave to File Suppl. Br., ECF
No. 45. This Court granted the motion, and Ms. Hutchinson filed
her renewed Motion to Dismiss, see Mot. to Dismiss, ECF No. 52;
which Mr. Bobulinski opposed, see Opp’n, ECF No. 55; and to
which Ms. Hutchinson filed a Reply, Reply, ECF No. 56. The
motion is ripe and ready for the Court’s adjudication.
II. 	Legal Standard
A. Motion to Dismiss
A motion to dismiss pursuant to Federal Rule of Civil
Procedure 12(b)(6) tests the legal sufficiency of a
complaint. Browning v. Clinton, 292 F.3d 235, 242 (D.C. Cir.
2002). A complaint must contain “a short and plain statement of
the claim showing that the pleader is entitled to relief, in
order to give the defendant fair notice of what the ... claim is
and the grounds upon which it rests.” Bell Atl. Corp. v.
Twombly, 550 U.S. 544, 555, (2007) (internal quotation marks
omitted).
Despite this liberal pleading standard, to survive
a motion to dismiss, a complaint “must contain sufficient
factual matter, accepted as true, to state a claim to relief
that is plausible on its face.” Ashcroft v. Iqbal, 556 U.S. 662,
678 (2009) (internal quotation marks omitted). “In determining
whether a complaint fails to state a claim, [the court] may
consider only the facts alleged in the complaint, any documents
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either attached to or incorporated in the complaint and matters
of which [the Court] may take judicial notice.” EEOC v. St.
Francis Xavier Parochial Schl., 117 F.3d 621, 624 (D.C. Cir.
1997). A claim is facially plausible when the facts pled in the
complaint allow the court to “draw the reasonable inference that
the defendant is liable for the misconduct alleged.” Id. The
standard does not amount to a “probability requirement,” but it
does require more than a “sheer possibility that a defendant has
acted unlawfully.” Id.
“[W]hen ruling on a defendant's motion to dismiss [pursuant
to Rule 12(b)(6)], a judge must accept as true all of the
factual allegations contained in the complaint.” Atherton v.
D.C. Office of the Mayor, 567 F.3d 672, 681 (D.C. Cir.
2009) (internal quotation marks omitted). In addition, the court
must give the plaintiff the “benefit of all inferences that can
be derived from the facts alleged.” Kowal v. MCI Commc'ns Corp.,
16 F.3d 1271, 1276 (D.C. Cir. 1994).
III. Analysis
A. Mr. Bobulinski Fails to State a Claim for Defamation
To state a defamation claim under District of Columbia law,2
the plaintiff must allege: “(1) that the defendant made a false
and defamatory statement concerning the plaintiff; (2) that the
2 The parties do not dispute that District of Columbia law
applies.
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defendant published the statement without privilege to a third
party; (3) that the defendant's fault in publishing the
statement amounted to at least negligence; and (4) either that
the statement was actionable as a matter of law irrespective of
special harm or that its publication caused the plaintiff
special harm.” Solers, Inc. v. Doe, 977 A.2d 941, 948 (D.C.
2009) (quoting Oparaugo v. Watts, 884 A.2d 63, 76 (D.C. 2005)
(quoting Crowley v. North Am. Telecomms. Ass'n, 691 A.2d 1169,
1173 n.2 (D.C. 1997)). “The third element, fault, depends on
whether the plaintiff is a public figure, subject to the
heightened actual malice standard of proof, or is instead a
private individual, subject to the lower negligence standard.”
Barrett v. Atlantic Monthly Group, LLC, Civil Action No. 22-49,
2024 WL 4119400 (D.D.C. Sept. 9, 2024) (citing Competitive
Enter. Inst. v. Mann, 150 A.3d 1213, 1240 n.33 (D.C. 2016)).
“[I]t is the role of the court to determine whether the
challenged statement is ‘capable of bearing a particular
meaning’ and whether ‘that meaning is defamatory’”. Tavoulareas
v. Piro, 817 F.2d 762, 779 (D.C. Cir. 1987) (en banc) (quoting
Restatement (Second) of Torts § 614(i), at 311 (1977)), cert.
denied, 484 U.S. 870 (1987). “A statement is defamatory ‘if it
tends to injure the plaintiff in his trade, profession or
community standing, or lower him in the estimation of the
community.’” Liberty Lobby, Inc. v. Dow Jones & Co., 838 F.2d
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1287, 1293–94 (D.C. Cir.) (quoting Howard Univ. v. Best, 484
A.2d 958, 988 (D.C. 1984)), cert. denied, 488 U.S. 825 (1988).
“[A]n allegedly defamatory remark must be more than unpleasant
or offensive; the language must make the plaintiffs appear
‘odious, infamous, or ridiculous.’” Best, 484 A.2d at 989
(quoting Johnson v. Johnson Publ'g Co., 271 A.2d 696, 697 (D.C.
1970)). In deciding whether a statement is capable of a
defamatory meaning, “the publication must be considered as a
whole, in the sense it would be understood by the readers to
whom it was addressed.” Best, 484 A.2d at 989 (citation
omitted). “‘Context’ is a critical legal concept for determining
whether, as a matter of law, a statement is reasonably capable
or susceptible of a defamatory meaning.” Klayman v. Segal, 783
A.2d 607, 614 (D.C. Cir. 2001).
The court is not to dismiss a complaint alleging defamation
pursuant to Rule 12(b)(6) if “the communications of which the
plaintiff complains were reasonably susceptible of a defamatory
meaning.” Id. at 612 (quoting Wallace v. Skadden, Arps,
Slate, Meagher & Flom, 715 A.2d 873, 875 (D.C. 1998); see also
Weyrich, supra, 344 U.S. App. D.C. at 255, 235 F.3d at 627
(“Whether a statement is capable of defamatory meaning is a
question of law, but ‘it is only when the court can say that the
publication is not reasonably capable of any defamatory meaning
and cannot be reasonably understood in any defamatory sense that
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it can rule as a matter of law, that it was not libelous.’”)
(quoting White v. Fraternal Order of Police, 909 F.2d 512, 518
(D.C. Cir. 1990) (quoting Levy v. American Mut. Ins. Co., 196
A.2d 475, 476 (D.C. 1964))). “The plaintiff has the burden of
proving the defamatory nature of the publication [citation
omitted], and the publication must be considered as a whole, in
the sense in which it would be understood by the readers to whom
it was addressed.” Best, 484 A.2d at 989 (citation omitted).
Mr. Bobulinski agrees that while the statement that Mr.
Meadows handed Mr. Bobulinski a sheet of paper or envelope “by
itself may not be defamatory,” it becomes defamatory “when
considered in the inflammatory context as was intended.” Opp’n,
ECF No. 55 at 9-10. Mr. Bobulinski argues that the “statements
occurred in the context of her book,” which “tells Ms.
Hutchinson’s story about what supposedly led her to testify
about January 6, 2021, and its aftermath,” and “her description
of the subject meeting.” Id. at 10. Mr. Bobulinski argues that
this context “plausibly implies Mr. Bobulinski’s meeting with
Mr. Meadows had something to do with the leadup to the events on
January 6, 2021, and why [Ms. Hutchinson] testified. Accusing
Mr. Bobulinski of involvement with the events of January 6,
2021, is defamatory as it implies potential criminal conduct and
is likely to subject him to contempt from the community at
large.” Id. at 11.
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Mr. Bobulinski also points to Ms. Hutchinson’s “grim
rhetoric” about the meeting. Id. Specifically, he points to Ms.
Hutchinson’s statements that “she ‘had a weird feeling that
[she] was in danger,’ and the feeling ‘was real,’” id. (quoting
Am. Compl., ECF No. 20 ¶ 49); that “[s]he whined ‘with childlike
desperation’ to Mr. Meadows that the meeting was not a good
idea, was ‘really stupid’ and that she ‘could not shake the
feeling that [she] had been entangled in something far more
complex and secretive than [she] had initially realized,’” id.
(quoting Am. Compl., ECF No. 20 ¶ 49); that she had “a ‘pit in
[her] stomach’ after the meeting and feeling ‘shame’ and that
she had ‘betrayed the world,’” id. (quoting Am. Compl., ECF No.
20 ¶ 61). Mr. Bobulinski concludes that “the reasoning for why
[Ms. Hutchinson] wrote the book, and her surrounding statements
about the meeting, provide sufficient context to give a
defamatory meaning to [Ms. Hutchinson’s] statement that Mr.
Meadows secretly handed Mr. Bobulinski ‘what appeared to be a
folded sheet of paper or a small envelope.’” Id. at 11- 12.
The Court concludes, as a matter of law, that the statement
and the context in which it was made—both the reason Ms.
Hutchinson wrote the book and her “grim rhetoric”—are not
reasonably susceptible of the defamatory meaning Mr. Bobulinski
suggests. The statement coupled with reason Ms. Hutchinson wrote
the book does not reasonably imply that the meeting had
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something to do with January 6, 2021 and the reason Ms.
Hutchinson chose to testify about it. The meeting between Mr.
Bobulinski and Mr. Meadows occurred on November 1, 2020, prior
to the 2020 presidential election and nearly two months before
January 6, 2021. Furthermore, Mr. Bobulinski does not point to
any specific language in the book that would support this
connection.
The “grim rhetoric” Mr. Bobulinski points to consists of
Ms. Hutchinson’s feelings about the meeting. “[I]f it is plain
that a speaker is expressing a subjective view, an
interpretation, a theory, conjecture, or surmise, rather than
claiming to be in possession of objectively verifiable facts,
the statement is not actionable.” Guilford Transp. Indus., Inc.
v. Wilner, 760 A.2d 580, 597 (D.C. 2000) (quotation omitted). In
other words, “a statement of opinion is actionable if—but only
if—it has an explicit or implicit factual foundation and is
therefore objectively verifiable.” Rosen v. American Israel
Public Affairs Committee, Inc., 41 A.3d 1250, 1256 (D.C.
2012)(citation omitted). Mr. Bobulinski argues that Ms.
Hutchinson’s “factual descriptions imply something illicit,
immoral, or illegal was occurring” and that because this is
“provably false,” her statements are actionable. Opp’n, ECF No.
55 at 13. However, Ms. Hutchinson does not claim in the
statements Mr. Bobulinski cites “to be in possession of
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objectively verifiable facts.” Nor do the statements imply that
there is a factual foundation for them. Rather, Ms. Hutchinson
discusses her feelings about the meeting. Finally, the
statements Mr. Bobulinski points to cannot be proven false. It
cannot be proven false that Ms. Hutchinson had the various
feelings she described having about the meeting.
For all these reasons, Mr. Bobulinski fails to state a
claim for defamation. Because the Court has determined that, as
a matter of law, the statement is not defamatory, the Court need
not reach whether Mr. Bobulinski qualifies as a limited purpose
public figure nor whether the statement was made with negligence
or malice. Accordingly, Mr. Bobulinski’s claim for defamation is
DISMISSED.
B. Mr. Bobulinski Fails To State a Claim for Defamation
By Implication
“In a defamation by implication case under D.C. law, ‘the
courts are charged with the responsibility of determining
whether a challenged statement is capable of conveying a
defamatory meaning.’” Tah v. Glob. Witness Publ'g, Inc., 991
F.3d 231, 239–40 (D.C. Cir. 2021) (quoting White v. Fraternal
Order of Police, 909 F.2d 512, 518 (D.C. Cir. 1990) (internal
quotation marks omitted). “A plaintiff must show first that the
‘communication, viewed in its entire context, ... conveys
materially true facts from which a defamatory inference can
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reasonably be drawn,’ and second, that ‘the communication, by
the particular manner or language in which the true facts are
conveyed, supplies additional, affirmative evidence suggesting
that the defendant intends or endorses the defamatory
inference.’” Id. at 240 (quoting Armstrong v. Thompson, 80 A.3d
177, 184 (D.C. 2013) (emphasis omitted) (quoting White, 909 F.2d
at 520)). “A defamation by implication stems not from what is
literally stated, but from what is implied.” White, 909 F.2d at
518 (citing Tavoulareas, 817 F.2d at 780).
Mr. Bobulinski argues that he has stated a claim for
defamation by implication because while Ms. Hutchinson “gave a
series of true facts”—specifically “that Mr. Bobulinski met with
Mr. Meadows at a Trump rally in Rome, Georgia,” she “included
her own inflammatory commentary to make [the meeting] appear
illicit, immoral, or illegal.” Opp’n, ECF No. 55 at 18-19. Mr.
Bobulinski argues that even if Ms. Hutchinson’s “descriptions of
how she felt about Mr. Bobulinski’s meeting with Mr. Meadows may
have been opinion, that is of no consequence because the
implication is a provable fact. Indeed, [Ms. Hutchinson] gave
the implication Mr. Bobulinski, in his meeting with Mr. Meadows,
was involved in something illicit or illegal. This can be proven
true or false, removing it from the protections of opinion.” Id.
at 19.
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In support, Mr. Bobulinski first cites Parnigoni v. St.
Columba’s Nursery School for “where context is important.” In
Parnigoni, a nursery school sent letters to parents of children
attending the school that identified the plaintiff, a teacher at
the school, as the wife of a convicted sex offender, and
suggested to the parents that the information provided may
impact their decisions about the safety of their children.
Parnigoni v. St. Columba’s Nursery School, 681 F. Supp. 2d 1, 15
(D.D.C. 2010). The court found that “the letters and the
circumstances surrounding their dissemination” “reasonably
implied” that the plaintiff “posed a danger to children as a
result of her decision to marry” her husband. Id. Mr. Bobulinski
argues that this is similar because Ms. Hutchinson’s
“description of the meeting, appearing in a book about the lead
up to January 6, 2021–makes it appear as if Mr. Bobulinski was
involved in an immoral or illegal scheme, as part of the lead up
to January 6, 2021, simply by virtue of the fact that he met
with Mr. Meadows in private at a rally for President Trump.”
Opp’n, ECF No. 55 at 21. The Court has already rejected this
argument supra.
Next, Mr. Bobulinski cites Barrett v. Atl. Monthly Grp.
LLC. In Barrett, the court found that a magazine editor’s
statement that a journalist was hoping to “disguise” past
accusations “of plagiarism and journalistic malfeasance” by
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using her married name in a byline, and that the outlet should
have used her original name in “the interest of transparency to
[its] readers” was capable of defamatory meaning. Barrett, 2024
WL 4119400, at *13. The court found that this statement would
lead a reasonable reader to “believe the negative implications
of the statements” because no other truthful facts related to
the reporter or the byline were presented, and the statement
contained an “implicit factual foundation” that was “objectively
verifiable.” Id. at *14 (citations omitted). Mr. Bobulinski
argues that this case helps him because Ms. Hutchinson “only
presented her negative context of the meeting between Mr.
Bobulinski and Mr. Meadows, leaving no room for other
interpretation.” Opp’n, ECF No. 55 at 22. The Court disagrees. A
reasonable reader could “draw his or her own conclusions” about
the nature of the meeting since the statements are based on her
subjective feelings. Barrett, 2024 WL 4119400, at *14.
Furthermore, in both Parnigoni and Barrett there is
“affirmative evidence suggesting that the defendant intends or
endorses the defamatory inference.” Armstrong, 80 A.3d at 184
(emphasis omitted) (quoting White, 909 F.2d at 520). In
Parnigoni, such evidence was the suggestion that a criminal
conviction should inform parents’ decisions about their
children’s safety; in Barrett, such evidence was the statement
that the plaintiff attempted to conceal her maiden name and past
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mistakes associated with it. Parnigoni, 681 F. Supp. 2d at 13;
Barrett, 2024 WL 4119400, at *14. But here, Ms. Hutchinson’s
remarks point to feelings of suspicion, unease, and that
something “complex” and “secretive” was afoot. Mot. to Dismiss,
ECF No. 52 at 12 (citing Compl., ECF No. 1 ¶¶ 49, 61). Ms.
Hutchinson “stopped short” of an actual accusation of
wrongdoing.
For all these reasons, the Court concludes, as a matter of
law, that the challenged statements do not imply a defamatory
meaning. Accordingly, Mr. Bobulinski’s claim for defamation by
implication is DISMISSED.
C. Mr. Bobulinski Fails to State a Claim for False Light
Invasion of Privacy
A claim for false light invasion of privacy “requires a
showing of (1) publicity, (2) about a false statement,
representation or imputation, (3) understood to be of and
concerning the plaintiff, and (4) which places the plaintiff in
a false light that would be offensive to a reasonable person.”
Blodgett v. Univ. Club, 930 A.2d 210, 222 (D.C. 2007) (quoting
Oparaugo v. Watts, 884 A.2d 63, 76 (D.C. 2005). Where a
plaintiff relies on the same underlying conduct to assert claims
for defamation and invasion of privacy, those claims may be
analyzed in a “like manner.” Harrison v. Washington Post Co.,
391 A.2d 781, 784 n.8 (D.C. 1978). The Court has found, as a
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matter of law, that Ms. Hutchinson’s statements are not
reasonably susceptible of a defamatory meaning. Therefore, Mr.
Bobulinski’s claim for false light invasion of privacy also
fails. See Klayman, 783 A.2d at 619 (finding that challenged
statement was not defamatory and “for the same reasons” did not
place the plaintiff in a false light and noting that a
“plaintiff may not avoid the strictures of the burdens of proof
associated with defamation by resorting to a claim of false
light invasion”) (internal citations and quotation marks
omitted).
Furthermore, Mr. Bobulinski’s reliance on White v.
Fraternal Order of Police is unavailing. In White, the defendant
publicized that the plaintiff tested positive for marijuana,
that a laboratory subsequently produced a negative result but it
“should easily have been confirmed,” and that the test samples
contained irregularities and were not handled according to
official procedures. White, 909 F.2d at 521-22. The plaintiff
argued that the defendant’s portrayal painted him in a false
light particularly given that “95% of positive test results at
the Clinic in the six months immediately preceding plaintiff's
test were erroneous.” Id. The Court of Appeals for the D.C.
Circuit held that whether the defendant’s statement portrayed
the plaintiff in a false light was a question for the jury
because it was “reasonable for a reader to infer that White used
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an illegal drug.” Id. at 522. However, Ms. Hutchinson’s
description of the meeting between Mr. Bobulinski and Mr.
Meadows, accompanied by her subjective feelings of unease, would
not be as “highly offensive to a reasonable person” as implying
illegal drug use. White, 909 F.2d at 522.
Accordingly, Mr. Bobulinski’s claim for false light
invasion of privacy is DISMISSED.
V. Conclusion
For the reasons set forth above, the Court GRANTS Ms.
Hutchinson’s Motion to Dismiss, ECF No. 52; and DISMISSES the
case without prejudice.
An appropriate Order accompanies this Memorandum Opinion.
SO ORDERED.
Signed: 	Emmet G. Sullivan
United States District Judge
March 24, 2026
Case 1:25-cv-00771-EGS Document 58 Filed 03/24/26 Page 19 of 19