govinfo:USCOURTS-dcd-1_25-cv-00771-0

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 HUTCHINSON, 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 HUTCHINSON, 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 
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