In December 2019, Playboy model Karen McDougal sued Fox News after Carlson, in a 2018 episode of his show, accused her of extorting Donald Trump. In September 2020, federal judge Mary Kay Vyskocil dismissed the lawsuit, citing her acceptance of Fox News's defense that Carlson's extortion claims were opinion-based and not "statements of fact". The judge also agreed with Fox News's defense that reasonable viewers would have "skepticism" over statements Carlson makes on its show, as he often engages in "exaggeration" and "non-literal commentary" and that Carlson is not "stating actual facts" on its show.
