Lim v. New York State Board of Law Examiners

Background

Khor Chin Lim, proceeding without a lawyer, sued several defendants in March 2025. The defendants included the New York State Board of Law Examiners, Cook County in Illinois, the City of Chicago, and former Presidents Joseph Biden and Barack Obama. Judge Ryu granted Lim permission to proceed without paying the filing fee but found during the required screening that Lim had not stated a claim for relief. Judge Ryu allowed Lim to file an amended complaint.

Lim did not timely file an amended complaint. Judge Ryu then recommended dismissal for failure to prosecute, meaning failure to move the case forward. Lim did not object. The court adopted that recommendation and dismissed the case without prejudice.

Temporary Restraining Order

Lim later filed an ex parte motion for a temporary restraining order, or TRO, which is emergency court relief intended to preserve the situation temporarily. Because the handwritten papers were difficult to read, the court understood Lim to be asking the court to prevent certain property from being sold, transferred, or otherwise disposed of, and to bar the district attorney in Rock County, Wisconsin, from seizing certain property. Lim appeared to argue that proceeds from a sale should not be used to prosecute him in Wisconsin.

The court denied the TRO. It applied the requirements that Lim show a likelihood of success on the merits, a likelihood of irreparable harm without relief, that the balance of equities favored him, and that the TRO served the public interest. The court found that Lim had not shown a likely chance of success. It described his assertions as conclusory or unsupported by evidence, including his arguments about an entity’s authority to sell or transfer property based on its registration and business form.

The court also noted uncertainty about its jurisdiction over the Wisconsin criminal prosecution. It referred to abstention under Younger, a doctrine that can limit federal-court interference with certain ongoing state proceedings, and to personal jurisdiction. Although Lim mentioned a narrow bad-faith exception to Younger abstention, the court found that he had not shown that the exception applied. The court stated that the personal-jurisdiction problem remained even apart from Younger abstention.

Request to Alter or Amend the Judgment

Lim also appeared to seek relief under Federal Rule of Civil Procedure 59(e), which permits a court to alter or amend a judgment in limited circumstances. The court explained that such relief may be appropriate for newly discovered evidence, clear error or a manifestly unjust initial decision, or an intervening change in controlling law.

The court found that Lim had not addressed that standard or explained why the finding that he failed to prosecute was incorrect based on the record. The court therefore declined to alter or amend the judgment. It also stated that, even if it considered Lim’s belated apparent desire to litigate, his claims lacked merit for the reasons discussed in the TRO analysis.

Disposition

The court denied Lim’s motion for a temporary restraining order and declined to alter or amend the judgment. The order did not change the earlier dismissal without prejudice for failure to prosecute.