Magistrate Judge Denies Trump's Recusal Motion in BBC Libel Lawsuit

In a February 2026 order, Magistrate Judge Enjoliqué A. Lett of the U.S. District Court for the Southern District of Florida rejected Trump's motion to recuse her from his defamation lawsuit against the BBC. Trump's counsel argued that Lett's prior private practice representation of Orbis Business Intelligence Ltd. in the separate Trump v. Clinton case created an appearance of bias under 28 U.S.C. § 455(a). The judge found the recusal motion was procedurally defective, noting that Trump's counsel—who had appeared as appellate counsel in the earlier case—knew or should have known of her involvement yet waited over 160 days to raise the issue, constituting a waiver. On the merits, Lett concluded that representing an unrelated non-party in a different action does not, without more, create a reasonable appearance of impartiality concerns. She cited recent Eleventh Circuit precedent holding that a judge's prior representation of a party in unrelated matters does not disqualify them from hearing cases involving that party. The judge also noted that Trump v. Clinton was dismissed at the pleadings stage and never reached discovery, so any discovery issues in the current defamation case would not overlap with matters she previously handled.