Campbell v. State of Minnesota
- Nancy Brasel
- 0:24-cv-01788
- U.S. District Court · District of Minnesota
- 2
In Campbell v. State of Minnesota, Judge Brasel denied Clifton Scott Campbell's petition asking a federal court to overturn his state conviction, dismissed the case with prejudice, and declined to allow him to appeal.
Clifton Scott Campbell, a person in Minnesota state custody who sought federal court review of his state conviction. The ruling closes his federal habeas case and blocks further appeal unless a higher court grants a certificate of appealability.
What happened
In Campbell v. State of Minnesota (Case No. 24-CV-1788), Clifton Scott Campbell filed a petition in federal court asking the court to review and overturn his Minnesota state conviction, a legal procedure known as a petition for a writ of habeas corpus under 28 U.S.C. Section 2254, which allows people held in state custody to challenge their imprisonment in federal court.
A United States Magistrate Judge, Douglas L. Micko, issued a Report and Recommendation on August 20, 2025, recommending that the petition be denied. Neither Campbell nor the State of Minnesota filed any objections to that recommendation, so the district court reviewed it only for obvious ('clear') errors.
Finding no clear error in Magistrate Judge Micko's Report and Recommendation, Judge Brasel accepted it, denied the petition, and dismissed the case with prejudice — meaning Campbell cannot refile the same claim in this court. The court also declined to issue a certificate of appealability, which is a required permission slip that allows a habeas petitioner to appeal to a higher court; without it, Campbell cannot pursue a further appeal of this decision through the normal federal appeals process.
The detailed version
Case: Clifton Scott Campbell v. State of Minnesota, Case No. 24-CV-1788 (NEB/DLM), United States District Court, District of Minnesota.
Judge: Nancy E. Brasel, United States District Judge.
Background: Petitioner Clifton Scott Campbell filed a petition for a writ of habeas corpus pursuant to 28 U.S.C. § 2254, challenging his state custody under a Minnesota conviction or sentence. A § 2254 petition is the mechanism by which a person in state custody may seek federal court review of alleged constitutional violations in their state criminal proceedings.
Magistrate Judge Proceedings: United States Magistrate Judge Douglas L. Micko issued a Report and Recommendation (R&R) on August 20, 2025, recommending denial of the petition. The opinion does not detail the specific grounds of the petition or the specific reasoning in the R&R beyond the recommendation to deny.
Objections: No party — neither Campbell nor the State of Minnesota — filed objections to the R&R. Under Federal Rule of Civil Procedure 72(b) and Eighth Circuit precedent (Grinder v. Gammon, 73 F.3d 793 (8th Cir. 1996)), when no party objects, the district court reviews the R&R only for clear error rather than conducting a de novo (independent, from-scratch) review.
Rulings:
- The R&R was accepted.
- The § 2254 petition was denied.
- The action was dismissed with prejudice, barring refiling of the same claims.
- No certificate of appealability (COA) was issued. A COA is required under 28 U.S.C. § 2253(c) before a habeas petitioner may appeal a district court's denial to the circuit court. The denial of a COA means Campbell cannot proceed to the Eighth Circuit Court of Appeals on this ruling through standard appellate channels without first obtaining a COA from the circuit court itself.
Date of Order: October 6, 2025.
Reviewer note from the AI+
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.