Michel v. Rardin
- Nancy Brasel
- 0:25-cv-03547
- U.S. District Court · District of Minnesota
- 2
In Michel v. Rardin, Judge Nancy E. Brasel denied Kenyatta Michel's petition asking a federal court to order his release or review his imprisonment, and dismissed the case with prejudice, meaning he cannot refile it.
Federal prisoners, particularly those held at FMC Rochester, who seek to challenge their confinement through habeas petitions in the District of Minnesota. This order also illustrates the consequences of failing to object to a magistrate judge's report and recommendation.
What happened
In Michel v. Rardin, federal prisoner Kenyatta Michel filed a petition asking the court to review the legality of his confinement at FMC Rochester, a federal medical center in Minnesota. The petition was referred to U.S. Magistrate Judge Elizabeth Cowan Wright, who issued a Report and Recommendation on October 1, 2025, recommending that the petition be denied. Michel did not object to that recommendation within the allowed time.
Because no party objected to Magistrate Judge Wright's report, the district court reviewed it only for obvious mistakes — a lower standard than a full review. Finding no clear error in the magistrate judge's analysis, the court accepted the recommendation in full.
Judge Nancy E. Brasel entered the final order on November 10, 2025, denying the petition and dismissing the case with prejudice, which means Michel cannot bring the same claim again in this court. The court also denied as moot — meaning no longer necessary to decide — Michel's request to proceed without paying court filing fees, since the case itself was closed.
The detailed version
In Michel v. Rardin (Case No. 25-CV-3547 (NEB/ECW), D. Minn.), petitioner Kenyatta Michel, a prisoner at FMC Rochester (a federal medical center in Rochester, Minnesota), filed a petition for a writ of habeas corpus — a legal request asking a court to examine whether his imprisonment is lawful — against the facility's warden, Jared Rardin.
The case was referred to United States Magistrate Judge Elizabeth Cowan Wright, who issued a Report and Recommendation on October 1, 2025, recommending denial of the petition. The opinion does not set forth the substantive grounds for the recommendation; it only reflects that no party objected.
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 to a magistrate judge's report and recommendation, the district court reviews it only for clear error — a deferential standard under which the court will accept the recommendation unless it contains an obvious mistake. United States District Judge Nancy E. Brasel found no clear error and accepted the Report and Recommendation in full.
Judge Brasel's November 10, 2025 order: (1) accepted the Report and Recommendation; (2) denied the habeas petition; (3) dismissed the action with prejudice, barring refiling of the same claims; and (4) denied as moot Michel's application to proceed without paying filing fees (colloquially known as in forma pauperis status), since the underlying case was closed. Judgment was ordered to be entered accordingly.
The opinion does not describe the factual or legal basis for Michel's habeas claims, the warden's response (if any), or the magistrate judge's reasoning for recommending denial. Those details would appear in the Report and Recommendation (ECF No. 5), 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.