A speaker’s use of “loose, figurative” language can also determine whether his or her statement can reasonably be interpreted as a factual allegation. In Standing Comm. on Discipline of the United States Dist. Court v. Yagman, 55 F.3d 1430 (9th Cir.1995), we held that an attorney could not be sanctioned for accusing a district judge of being “dishonest” because the other terms the attorney used to describe the judge — “ignorant,” “ill-tempered,” “buffoon,” “sub-standard human,” and “right-wing fanatic”- — -made it clear that the attorney intended only to signal his general contempt for the judge, rather than to accuse him of corruption. Id. at 1440; see also Old Dominion Branch No. 196, Nat'l Ass’n of Letter Carriers v. Austin, 418 U.S. 264, 284, 94 S.Ct. 2770, 41 L.Ed.2d 745 (1974) (<HOLDING>); Cochran, 58 F.Supp.2d at 1124-25(holding that
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