Harold Jean-Baptiste v. United States Department of Justice

• Court: Court of Appeals for the Eleventh Circuit
• Decided: January 26, 2026
• Docket: 25-12805
• Status: Unpublished

Opinion

USCA11 Case: 25-12805 Document: 15-1 Date Filed: 01/26/2026 Page: 1 of 4

NOT FOR PUBLICATION

In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 25-12805 Non-Argument Calendar ____________________

HAROLD JEAN-BAPTISTE, Plaintiff-Appellant, versus

UNITED STATES DEPARTMENT OF JUSTICE, U.S. ATTORNEY GENERAL, FEDERAL BUREAU OF INVESTIGATION (FBI), DIRECTOR OF THE FEDERAL BUREAU OF INVESTIGATION, CIVIL PROCESS CLERK FOR THE U.S. ATTORNEY'S OFFICE FOR THE SOUTHERN DISTRICT OF FLORIDA, Defendants-Appellees. USCA11 Case: 25-12805 Document: 15-1 Date Filed: 01/26/2026 Page: 2 of 4

2 Opinion of the Court 25-12805 ____________________ Appeal from the United States District Court for the Southern District of Florida D.C. Docket No. 1:25-cv-23412-EGT ____________________

Before NEWSOM, BRASHER, and KIDD, Circuit Judges. PER CURIAM: Harold Jean-Baptiste, pro se, appeals from the magistrate judge’s August 5, 2025 order dismissing his case with prejudice. We lack jurisdiction to review that order for the reasons explained below. Jean-Baptiste filed a complaint on July 29, 2025. The follow- ing day, a magistrate judge entered an order informing the parties that the case had been assigned to a magistrate judge and that they could opt out of the magistrate judge’s jurisdiction by filing a mo- tion for case reassignment or consent to it by filing a statement of consent. The order further provided that, if a party did not file a motion for case reassignment within 14 days from that date or “14 days from the last appearance by any party joined in the action (whichever [was] later),” that party would be deemed to have con- sented to the magistrate judge’s jurisdiction. Additionally, the or- der noted that the parties could impliedly consent by continuing to file documents without submitting a motion for case reassignment. Six days later, on August 5, 2025, the magistrate judge dis- missed the case with prejudice. USCA11 Case: 25-12805 Document: 15-1 Date Filed: 01/26/2026 Page: 3 of 4

25-12805 Opinion of the Court 3

On appeal, a jurisdictional question asked the parties to ad- dress whether all parties to the action had consented to a magis- trate judge conducting the proceedings, but no responses were re- ceived. We lack jurisdiction over Jean-Baptiste’s appeal because the parties did not consent to the magistrate judge’s jurisdiction. See United States v. Schultz, 565 F.3d 1353, 1359 (11th Cir. 2009) (explain- ing that this Court generally lacks jurisdiction to hear appeals di- rectly from magistrate judge orders); 28 U.S.C. § 636(c)(1) (provid- ing that parties to an action may voluntarily consent to a magistrate judge exercising jurisdiction over “any or all proceedings in a jury or nonjury civil matter” and to “order the entry of judgment”). The defendants, who did not appear in the action, did not consent to the magistrate judge conducting the proceedings, and Jean-Bap- tiste did not file any document in the district court reflecting that he expressly consented to the magistrate judge’s jurisdiction. See Barnett v. Gen. Elec. Cap. Corp., 147 F.3d 1321, 1322 (11th Cir. 1998) (providing that a party must clearly and unambiguously consent to a magistrate judge’s jurisdiction under § 636(c)(1)). Furthermore, Jean-Baptiste’s implied consent cannot be in- ferred from his conduct during the proceedings. See Roell v. Withrow, 538 U.S. 580, 582 (2003) (holding that consent can be “in- ferred from a party’s conduct during litigation”). Jean-Baptiste’s failure to file a motion for case reassignment did not constitute im- plied consent because he was not afforded the requisite oppor- tunity to file such a motion or otherwise object to the magistrate USCA11 Case: 25-12805 Document: 15-1 Date Filed: 01/26/2026 Page: 4 of 4

4 Opinion of the Court 25-12805

judge’s jurisdiction. See Roell, 538 U.S. at 582, 589-91. Furthermore, Jean-Baptiste’s conduct did not demonstrate that he voluntarily proceeded before the magistrate judge after being informed of his right to refuse to do so. See id. at 590 (providing that implied con- sent exists when “the litigant or counsel [is] made aware of the need for consent and the right to refuse it, and still voluntarily appear[s] to try the case before the Magistrate Judge”). Accordingly, this appeal is DISMISSED for lack of jurisdic- tion. All pending motions are DENIED as moot.