Dahir v. Bolin
- Eric Tostrud
- 0:24-cv-01304
- U.S. District Court · District of Minnesota
- 2
In Dahir v. Bolin, Judge Tostrud denied Mohammed Abdi Dahir's petition challenging his imprisonment at MCF Stillwater, dismissed the case entirely, and ruled that no appeal may be taken.
Mohammed Abdi Dahir, a prisoner at MCF Stillwater in Minnesota who was challenging his confinement in federal court. His petition was denied and he has been denied permission to appeal.
What happened
In Dahir v. Bolin, Mohammed Abdi Dahir, a prisoner at MCF Stillwater in Minnesota, filed a petition in federal court asking to be released or have his custody reviewed — a type of legal challenge known as a petition for a writ of habeas corpus. He also asked the court to add materials to the record and to pause the proceedings while he pursued other remedies.
Magistrate Judge Elizabeth Cowan Wright issued a Report and Recommendation on September 30, 2025, recommending that the petition and related motions be denied. Neither party objected to that recommendation, so the presiding judge reviewed it only for obvious legal errors — a lower standard than a full review.
Finding no clear error, Judge Tostrud accepted the Report and Recommendation in full. The petition was denied and the case was dismissed. Dahir's motion to add to the record and his motion to pause the proceedings were also denied. The court further ruled that no certificate of appealability — a required permission slip allowing a prisoner to appeal such a ruling to a higher court — will be issued, which means Dahir cannot appeal this decision through the standard route.
The detailed version
This case arises from a habeas corpus petition filed by Mohammed Abdi Dahir (Petitioner), a prisoner held at MCF Stillwater, against William Bolin, the Warden of that facility (Respondent), under File No. 24-cv-1304. A habeas corpus petition is a federal legal mechanism through which a prisoner challenges the lawfulness of his confinement.
Magistrate Judge Elizabeth Cowan Wright issued a Report and Recommendation (R&R) on September 30, 2025 (ECF No. 41), recommending denial of the petition and all related motions. When no party objects to an R&R within the prescribed period, the district court reviews it only for clear error under Federal Rule of Civil Procedure 72(b), citing Grinder v. Gammon, 73 F.3d 793, 795 (8th Cir. 1996).
District Judge Eric C. Tostrud reviewed the R&R under that clear-error standard, found none, and on October 29, 2025 issued a one-page order with the following dispositions: (1) the R&R is accepted; (2) Dahir's Amended Petition (ECF No. 31) is denied and the action is dismissed; (3) Dahir's Motion to Supplement the Record (ECF No. 36) is denied; (4) Dahir's Motion to Stay the Habeas Corpus Petition (ECF No. 40) is denied; and (5) no certificate of appealability (COA) shall issue. A COA is a prerequisite for appealing a habeas denial to the circuit court; its denial here forecloses the standard appellate path for Dahir.
The order does not disclose the underlying facts of Dahir's conviction or the specific grounds raised in his petition, as those details are contained in the R&R, which is not reproduced here.
Reviewer note from the AI+
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.