Harold Jean-Baptiste v. DOJ

• Court: Court of Appeals for the D.C. Circuit
• Decided: March 24, 2026
• Docket: 25-5458
• Status: Unpublished

Opinion

United States Court of Appeals FOR THE DISTRICT OF COLUMBIA CIRCUIT ____________ No. 25-5458 September Term, 2025 1:25-cv-04303-UNA Filed On: March 24, 2026 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, Pillard, 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 and the motion for other relief, it is

ORDERED that the motion for other relief be denied. Appellant has failed to demonstrate any entitlement to the relief sought. It is

FURTHER ORDERED AND ADJUDGED that the district court’s December 12, 2025 minute order be affirmed. Appellant has not shown that the district court erred by denying him leave to file his complaint because the complaint fails to satisfy the standard set forth in Federal Rule of Civil Procedure 8(a) and contains the same type of frivolous claims that appellant has been enjoined from asserting. See Jean-Baptiste v. Dep’t of Justice, No. 1:23-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 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). 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.”). United States Court of Appeals FOR THE DISTRICT OF COLUMBIA CIRCUIT ____________ No. 25-5458 September Term, 2025

Pursuant to D.C. Circuit Rule 36, this disposition will not be published.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