Harold Jean-Baptiste v. DOJ
Harold Jean-Baptiste v. DOJ
Opinion
United States Court of Appeals FOR THE DISTRICT OF COLUMBIA CIRCUIT ____________ No. 24-5087 September Term, 2025 1:24-cv-01040-ACR Filed On: December 10, 2025 Harold Jean-Baptiste,
Appellant
v.
United States Department of Justice, et al.,
Appellees
ON APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
BEFORE: Henderson, Wilkins, and Pan, Circuit Judges
JUDGMENT
This appeal was considered on the record from the United States District Court for the District of Columbia and on the brief filed by appellant. See Fed. R. App. P. 34(a)(2); D.C. Cir. Rule 34(j). Upon consideration of the foregoing, the motion to amend the complaint, the motion to obtain Freedom of Information Act data, the motion to stop and set aside national security letters, and the motion to appoint counsel, it is
ORDERED that the motion to amend the complaint, the motion to obtain Freedom of Information Act data, and the motion to stop and set aside national security letters be denied. Appellant has failed to demonstrate any entitlement to the relief sought. It is
FURTHER ORDERED that the motion to appoint counsel be denied. In civil cases, appellants are not entitled to appointment of counsel when they have not demonstrated any likelihood of success on the merits. It is
FURTHER ORDERED AND ADJUDGED that the district court’s April 12, 2024 and August 21, 2025 orders be affirmed. The district court correctly dismissed appellant’s complaint based on a pre-filing injunction requiring him to obtain leave of court before filing any pro se complaint. See Jean-Baptiste v. Dep’t of Justice, No. 23- cv-02298 (D.D.C. Jan. 18, 2024). To the extent appellant challenges the pre-filing injunction on First Amendment grounds, appellant did not appeal that order, and he is United States Court of Appeals FOR THE DISTRICT OF COLUMBIA CIRCUIT ____________ No. 24-5087 September Term, 2025
thus precluded from litigating the issue in this case. See Allen v. McCurry, 449 U.S. 90, 94 (1980); see also Martin-Trigona v. United States, 779 F.2d 72, 73 (D.C. Cir. 1985) (per curiam). The district court also correctly denied appellant’s motion for leave to file and for reconsideration because the amended complaint fails to satisfy the standard set forth in Fed. R. Civ. P. 8(a) and contains the same type of frivolous claims that appellant has been enjoined from asserting. Finally, appellant’s allegations of judicial bias are without merit. See Liteky v. United States, 510 U.S. 540, 555 (1994) (“[J]udicial rulings alone almost never constitute a valid basis for a bias or partiality motion.”).
Pursuant to D.C. Circuit Rule 36, this disposition will not be published. The Clerk is directed to withhold issuance of the mandate herein until seven days after resolution of any timely petition for rehearing or petition for rehearing en banc. See Fed. R. App. P. 41(b); D.C. Cir. Rule 41.
Per Curiam
FOR THE COURT: Clifton B. Cislak, Clerk
BY: /s/ Daniel J. Reidy Deputy Clerk
Page 2
Reference
- Status
- Unpublished