Barnett v. Letitia Ann James
- Karas
- 7:26-cv-03048
- U.S. District Court · Southern District of New York
- 2
Barnett v. James: Judge Karas denied Barnett’s renewed preliminary-injunction request because he showed no material change in circumstances.
Andre Nigel Barnett’s renewed request for emergency injunctive relief was denied; the order also addressed how he should submit future filings about his state-court case.
What happened
In Andre Nigel Barnett v. Letitia Ann James, et al., Barnett filed letters about his state-court case and refiled two earlier requests for emergency relief. The court treated the filings as a renewed request for a preliminary injunction.
The court said it had already warned Barnett that repeated emergency requests without a significant change in circumstances could be denied. It found that new disputes in the state case, including a judge’s refusal to let Barnett read a disqualification motion into the record, did not materially change the earlier analysis.
Judge Kenneth M. Karas denied the renewed request for a preliminary injunction. He also told Barnett that routine updates and repeated allegations about the state-court case were not helpful and that future filings should follow the federal rules, the court’s rules, or specific court orders.
The detailed version
- Barnett v. Letitia Ann James · No. 7:26-cv-03048
- Karas
- July 17, 2026
Background
On July 14, 2026, Andre Nigel Barnett filed several letters concerning proceedings in his state-court case and refiled two earlier motions seeking emergency injunctive relief. The court considered whether those filings amounted to a renewed motion for a preliminary injunction.
Court’s Analysis
The court had previously warned Barnett that additional applications for emergency relief could be summarily denied if there had been no material change in circumstances. The court incorporated its earlier reasons for denying emergency relief.
The court concluded that new disputes in Barnett’s state-court case did not materially change that analysis. It specifically stated that a state-court judge’s refusal to allow Barnett to read a motion seeking mandatory disqualification into the record did not, by itself, show that Barnett had been denied an opportunity to raise the issue before a legally trained judge before sentencing. The court also noted that, absent statutory grounds, recusal is inherently discretionary. In discussing abstention under the Younger doctrine—a principle that can limit federal-court interference with certain ongoing state proceedings—the court found no material change relevant to emergency injunctive relief.
Disposition
To the extent Barnett intended his filings to be a renewed motion for a preliminary injunction, the court denied it. The order did not decide the state-court case. The court also advised Barnett that routine updates about that case and repeated allegations from the complaint or earlier filings were not helpful, and that submissions should follow the Federal Rules of Civil Procedure, the court’s Individual Rules, or a specific court order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.