According to Deadline, Sony has made a pre-emptive deal for the feature, which would feature Sandler and James as parking valets at a South Beach Hotel.
The film would follow the stars as they go on the run after witnessing a murder.
James will write the script with former King of Queens producer Nick Bakay. The pair also wrote Paul Blart: Mall Cop.
Sandler and James previously starred together in the hit comedies Grown Ups and I Now Pronounce You Chuck & Larry.