Circuit Judge Dan Vaughn said he didn't have the authority to issue an injunction ordering the recount of 37,379 early-voting ballots West sought after problems were discovered in the counting of early ballots on Election Night, The Palm Beach Post reported.
Vaughn's ruling effectively leaves the decision in the hands of the county's canvassing board, which was scheduled to meet Friday.
Unofficial returns show Democrat Patrick Murphy, in Washington for orientation, ahead by 1,907 votes or 0.58 percent, beyond the margin that triggers an automatic recount.
West hasn't conceded.
Vaughn said West has other legal options, citing a statute that allows a candidate to contest an election within 10 days of the final certification of results, which is scheduled for Tuesday.
The canvassing board originally planned a full recount of early votes after some were double-counted and others ignored on Election Night. However, the board later decided to recount only 16,275 ballots from three of the eight days of early voting.
That recount resulted in 799 early votes disappearing from the West-Murphy race. West had argued the irregularities that were discovered during the partial recount merited a full recount.
If the canvassing board decides to recount the early-voting ballots and West gets enough votes to pull within the 0.5 percentage point margin, a full recount could be triggered in the three counties that make up the 18th Congressional District -- northern Palm Beach, Martin and St. Lucie counties.