We determine the limit of the lowest achievable photoemitted electron temperature, and therefore the maximum achievable electron brightness, from unstructured photoemitting materials producing dense relativistic or nonrelativistic photoelectron beams. The limit is given by electron heating that occurs just after emission into vacuum, and is due to poorly screened Coulomb interactions equivalent to disorder induced heating seen in ultracold neutral plasmas. We first show that traditional analytic methods of Coulomb collisions fail for the calculation of this strongly coupled heating. Instead, we employ an N-body tree algorithm to compute the universal scaling of the disorder induced heating in fully contained bunches, and show it to agree well with a simple model utilizing the tabulated correlated energy of one component plasmas. We also present simulations for beams undergoing Coulomb explosion at the photoemitter, and demonstrate that both the temperature growth and subsequent cooling must be characterized by correlated effects, as well as correlation-frozen dynamics. In either case, the induced temperature is found to be of several meV for typical photoinjector beam densities, a significant fraction of the intrinsic beam temperature of the coldest semiconductor photocathodes. Thus, we expect disorder induced heating to become a major limiting factor in the next generation of photoemission sources delivering dense bunches and employing ultra-cold photoemitters.