A federal judge has dismissed Michael Avenatti’s defamation lawsuit against Fox News over the network’s coverage of his 2018 domestic violence arrest, ruling the self-described “fiercest, most vocal critic” to President Donald Trump didn’t meet the legal threshold required as a public figure to show actual malice.

Judge Stephanos Bibas of the U.S. Court of Appeals for the Third Circuit, sitting by designation in the District of Delaware, issued the order Aug. 13 as Avenatti was defending himself in his wire fraud trial in the U.S. District Court for the Central District of California, which alleges a broad scheme that defrauded clients of millions of dollars.