In Re DARNELL CARTER v. U.S. Dist. Ct. for D.C., 542 U.S. 367, 380 2004 cleaned Case: 26-110 Document: 12…

NOTE: This order is nonprecedential.
United States Court of Appeals
for the Federal Circuit
______________________
In Re DARNELL CARTER,
Petitioner
______________________
2026-110
______________________
On Petition for Writ of Prohibition to the United States
Court of Federal Claims in No. 1:25-cv-01884-RAH, Judge
Richard A. Hertling.
______________________
ON PETITION
______________________
Before REYNA, BRYSON, and STARK, Circuit Judges.
PER CURIAM.
O R D E R
The United States Court of Federal Claims ordered
Darnell Carter to show cause why his tax refund claims
should be not dismissed without prejudice for lack of juris-
diction, directing him to submit the documentation he filed
with the Internal Revenue Service to support that court’s
jurisdiction. Mr. Carter now petitions this court for a writ
of prohibition preventing enforcement of that order.
Issuance of a writ “is a drastic and extraordinary rem-
edy reserved for really extraordinary causes.” Cheney v.
U.S. Dist. Ct. for D.C., 542 U.S. 367, 380 (2004) (cleaned
Case: 26-110 Document: 12 Page: 1 Filed: 12/12/2025

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IN RE CARTER 2
up). A petitioner seeking such relief must show: (1) “no
other adequate means to attain the relief he desires,” (2) a
“clear and indisputable” right to relief, and (3) the writ is
“appropriate under the circumstances.” Id. at 380–81
(cleaned up). Mr. Carter has not shown a clear and indis-
putable right to relief or that he cannot raise his challenges
to the order on appeal after a final judgment.
Accordingly,
IT IS ORDERED THAT:
The petition is denied, and any pending motion is de-
nied.
December 12, 2025
Date
FOR THE COURT
Case: 26-110 Document: 12 Page: 2 Filed: 12/12/2025

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