Lee, who hosts a show on public access TV called Now See It Person To Person: Kurt Cobain Was Murdered, has said he will try again obtain the photos, and will file another lawsuit if unsuccessful.
He tells the Seattle Times, "I've never heard of a case where an issue of such public importance was dismissed because of such trivial circumstances."
The Nirvana frontman was found dead at his home in Seattle in April, 1994, with his official cause of death cited as suicide by a self-inflicted shotgun wound to the head.
However, sceptics believe the ruling is incorrect and Cobain's death was suspicious.
Special investigators examine the body of Kurt Cobain, which lies on the floor of a room atop the detached garage in his home overlooking Lake Washington in Seattle, 1994. Photo / AP
During Lee's court case, Cobain's daughter Frances Bean said that if the photographs were released, it would have lasting psychological effects on her and her family.
Bean said in a statement, "I have had to cope with many personal issues because of my father's death. Coping with even the possibility that those photographs could be made public is very difficult. Further sensationalising it through the release of these pictures would cause us indescribable pain."
Frances Bean Cobain, daughter of Kurt Cobain, with her mother and Cobain's widow Courtney Love. Photo / AP
