Nunes received the package in December 2019, when the Republican was the ranking member of the House Permanent Select Committee on Intelligence.
Maddow told viewers that Nunes "refused to hand it over to the FBI, which is what you should do if you get something from somebody who is sanctioned by the U.S. as a Russian agent."
The judge found no clear and convincing evidence that Maddow had a "high degree of awareness of probable falsity," or any evidence that "defendant's admitted political bias caused defendant to act with a reckless disregard of the truth."
Nunes' lawyers and Trump Media did not immediately respond on Monday to requests for comment. Lawyers for NBCUniversal did not immediately respond to similar requests.
The U.S. Treasury Department
sanctioned Derkach in September 2020 for trying to interfere in that year's U.S. presidential election to help Trump, who lost to Democrat Joe Biden.
Federal prosecutors in Brooklyn, New York
charged Derkach in December 2022 with unrelated money laundering and sanctions violations. He remains at large.
The case is Nunes v NBCUniversal Media Inc, U.S. District Court, Southern District of New York, No. 22-01633.
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