From Grenell v. Troye, decided yesterday by Judge Rossie Alston (E.D. Va.):
Plaintiff Richard Grenell … is a former Acting Director of National Intelligence and a former United States Ambassador. Plaintiff is a citizen of the State of California. Defendant Olivia Troye ("Defendant") is a former aide to former Vice President Michael Pence and owner of the Troye Group LLC, which … consults on political issues to the private sector.
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Plaintiff served as spokesman to four United States Ambassadors at the United Nations from 2001 to 2008…. Plaintiff became the United States Ambassador to Germany, serving his country from May 8, 2018, until June 1, 2020…. Plaintiff served as Acting Director of National Intelligence from February 20, 2020, to May 26, 2020. While Acting Director of National Intelligence, Plaintiff continued to serve as the Ambassador to Germany and was also a member of a special presidential envoy for Serbia and Kosovo peace negotiations…. In August of 2020, … he became a senior advisor to the Republican National Committee…. In December 2024, following the election of Donald Trump to a second term, Plaintiff was named the Presidential Envoy for Special Missions. In February of 2025, Plaintiff was also appointed by President Trump as the Interim Director of the Kennedy Center. Finally, in May of 2025, Plaintiff joined the Board of Directors at Live Nation.
On April 7, 2022, Plaintiff tweeted his opinion of the Biden Administration restricting its search for potential nominees for the open seat on the Supreme Court of the United States to certain minorities. An exchange of tweets ensued between Plaintiff and U.S. Congressman Ted Lieu. On April 8, 2022, U.S. Congressman Swalwell tweeted to Congressman Lieu a comment that Plaintiff hung out with Nazis during his time serving as the Ambassador to Germany. Plaintiff asserts that this was a lie. Congressman Lieu replied to Congressman Swalwell, asking if he had proof of this allegation.
Defendant then joined the conversation by tweeting that she did in fact have proof that Plaintiff associated with Nazis. Defendant went on to allege that Plaintiff tried to have Vice President Pence attend a white supremacist event while he was on an overseas trip. Plaintiff asserts that, in Germany, being a Nazi is a serious crime and that it is even a crime to openly sympathize with Nazis or promote Nazi ideas.
Plaintiff asserts that, despite knowing the serious ramifications of calling someone a Nazi and a white supremacist, and because Defendant is bitter toward Trump administration officials in general and Plaintiff in particular, Defendant deliberately lied about Plaintiff having ties to Nazis and of promoting Nazi ideology. Plaintiff asserts that Defendant did so with reckless disregard for the truth or falsity of her allegations. Plaintiff then tweeted to Defendant demanding that she back up her claims. Defendant chose not to respond to Plaintiff's tweet.
On April 9, 2022, Plaintiff again tweeted at Defendant following up on his request that she provide her proof or retract her tweet, stating "Olivia won't respond because she is slandering me." Plaintiff asserts that, to date, Defendant has not retracted her statement or produced any of her alleged proof. Plaintiff further asserts that Defendant's tweet was viewed by thousands, and multiple news outlets picked up Defendant's alleged lies, further spreading them. Plaintiff alleges that, Defendant, as an experienced political operative, knew that being a former aide to the vice president would elevate the reach and perceived credibility of her tweet….
{In [this] Court's [earlier] Memorandum Opinion and Order, the Court held that Plaintiff "cannot argue that merely being associated with certain interests is defamatory" … (citing American Conservative Unit v. Institute for Legislative Analysis (E.D. Va. 2025) (dismissing defamation claim premised on the allegation that plaintiffs were associated with influential persons and causes); Deripaska v. Assoc. Press (D.D.C. 2017) (dismissing defamation claim premised on allegation that plaintiff was associated with the interests of the Russian government)). Further, numerous courts have held that "[s]tatements indicating a political opponent is a Nazi … are odious and repugnant … [b]ut they are not actionable defamation …."); see also Jorjani v. New Jersey Inst. of Tech (D.N.J. 2019) ("[C]alling [the p]laintiff a 'white supremacist' is synonymous with calling [the p]laintiff 'racist,' and thus will not result in defamation liability."). Thus, this Court again finds that the statements alleged are not defamatory.}
Plaintiff argues that … Defendant's statement was more than an alleged association and was "a specific accusation about a specific event" whereas the other cases pertain to abstract name calling. But Plaintiff does not explain how that changes the analysis of whether the statement is capable of defamatory meaning.
Moreover, the part of the statement to which the Plaintiff apparently objects is not that Defendant alleged that Plaintiff invited the former Vice President but that he was associated with Nazis. As Plaintiff puts it, the defamatory portion of the statement is that Plaintiff "urged the Vice President to attend a white supremacist gathering." Although whether Plaintiff extended an invitation to the former Vice President to attend any event is a matter which is provably false, Plaintiff does not suggest that did not invite Vice President Pence anywhere during the trip to Germany. The defamatory portion of the statement is the reference to Nazis and, as courts recognize, whether a group qualifies as "Nazis" is an inactionable or opinion statement.
Despite the second opportunity to brief the issue, Plaintiff cites not a single case which reached a contrary result. Indeed, the case which Plaintiff cites, Deripaska, determined that the statements at issue were not capable of defamatory meaning. Deripaska ("Thus, even if the article falsely states that Deripaska and Manafort had a contract to promote Russian interests, as the Court assumes here, that statement fails to convey any defamatory meaning."). Plaintiff even implicitly concedes that non-actionable nature of the statement when he argues that the defamation relates to a "so-called white supremacist gathering." Accordingly, Plaintiff has failed to establish defamatory meaning.
Furthermore, Plaintiff fails to allege damages. Plaintiff's allegations regarding damages are conclusory and speculative and, in fact, Plaintiff pleads concrete facts suggesting that he was not damaged. Plaintiff alleges in conclusory fashion that he lost business opportunities, but he fails to identify a single such opportunity. Moreover, Plaintiff speculates that, "if he is affiliated with or believed to have promoted Nazi or white supremacist interests," then he receives less work. By contrast, Plaintiff acknowledges that, since these remarks were posted, he has: (i) received private equity opportunities overseas; (ii) been named the Presidential Envoy for Special Missions; (iii) been named the Interim Director of the Kennedy] Center; and (iv) joined the Board of Directors at Live Nation….
Thus, finding that Plaintiff has not pled facts sufficient to show defamatory meaning or damages, the Court will grant the Motion with respect to the defamation claim.
With respect to Plaintiff's [defamation per se claim, which wouldn't require proof of specific damage to reputation -EV], the Supreme Court of Virginia has recognized that certain words can constitute defamation per se: (i) those which impute to a person some serious crime involving moral turpitude; (ii) those which impute to a person a contagious disease; (iii) those which impute to a person unfitness to perform the duties of an office or employment; and (iv) those which prejudice such person in his or her profession or trade. The third category of defamation per se requires that "such statements damage [Plaintiff's] standing to engage in his … chosen profession and carry the connotation that he … lacks the integrity and fitness to [carry out his role]." For the fourth category, the Supreme Court of Virginia has noted, "[t]hat a defamatory statement may have had an adverse impact upon a plaintiff's work [but] does not make that statement per se defamatory where the defamation is not 'necessarily hurtful' to the plaintiff's business and does not touch upon the plaintiff in his special trade or occupation." This claim also fails for lack of defamatory meaning, but fails for the additional reasons that Plaintiff fails to establish defamation per se.…
Plaintiff does not allege any facts that assert that these statements impact his fitness or ability to perform his roles. Indeed, whether Plaintiff invited the former Vice President to attend any event does reflect on his particular duties as an Ambassador. Judges in this District have found that plaintiffs have failed to satisfy this standard even where the alleged defamatory comments relate to the plaintiff's termination so long as they do not "necessarily" reflect on the plaintiff's ability to perform his duties. Marroquin v. Exxon Mobil Corp. (E.D. Va. 2009) (accusation that plaintiff was terminated for doing something "very bad" was not defamation per se because it did "not establish the required nexus with Plaintiff's particular employment responsibilities or ability to perform his job that would support Plaintiff's claim of defamation per se"). Plaintiff has not met this standard.
The Court finds that Plaintiff's Amended Complaint similarly falls short in its attempt to allege facts sufficient to show that Defendant's statement subjects him to the prejudice required under the fourth category. Plaintiff identifies his trade or profession as diplomacy and/or national security. But … in Fleming v. Moore (Va. 1981), the Supreme Court of Virginia cited with approval a case determining that calling an ambassador a Communist was not defamation per se.… [O]ther courts have held that similar claims are not defamatory. See Guilford Trans. Indus., Inc. v. Wilner (D.C. 2000) ("[Defamation] necessarily, however, involves the idea of disgrace; and while a statement that a person is a [part of a certain political group] may very possibly arouse adverse feelings against him … it cannot be found in itself to be defamatory ….")…
Grace H. Williams and Thomas Mitchell Craig (FH&H PLLC) and Mark Steven Zaid (Mark S. Zaid, P.C.) represent defendant.
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