Hendrickson v. Beltz
- Jeffrey Bryan
- 0:25-cv-03410
- U.S. District Court · District of Minnesota
- 8
In Hendrickson v. Beltz, Judge Jeffrey M. Bryan denied Mark S. Hendrickson's petition asking a federal court to overturn his Minnesota first-degree criminal sexual conduct conviction, ruling that Hendrickson had failed to properly raise his claims in state court first and that his remaining claim involved only state law, which federal courts cannot review in this type of proceeding.
State prisoners seeking to challenge their convictions in federal court under 28 U.S.C. § 2254, particularly those who may not have properly raised their federal constitutional claims in state courts at each level before filing in federal court.
What happened
In Hendrickson v. Beltz, Mark S. Hendrickson, a Minnesota state prisoner serving a 172-month sentence for first-degree criminal sexual conduct following a 2018 Sherburne County jury conviction, filed a federal petition asking the court to release him or overturn his conviction. He raised ten grounds for relief, including that his trial and appellate lawyers were constitutionally ineffective, that the trial court lacked proper authority to hear his case, and that the trial court wrongly allowed testimony about prior bad acts to be heard by the jury.
Magistrate Judge David T. Schultz reviewed the petition and issued a Report and Recommendation concluding that nine of the ten claims had been 'procedurally defaulted' — meaning Hendrickson had not properly presented them to the state courts before coming to federal court — and that the tenth claim involved only a state evidence rule that federal courts cannot review in this type of case. Hendrickson objected, but the court found his objections too general and unsupported by specific legal arguments to require a fresh, detailed review.
Judge Jeffrey M. Bryan adopted the Magistrate Judge's recommendations in full, denied the petition, denied the motion to expand the court record, affirmed the earlier denial of Hendrickson's request for a court-appointed lawyer, and declined to issue a certificate of appealability — meaning Hendrickson did not receive permission from this court to pursue a further appeal on these grounds.
The detailed version
- Mark S. Hendrickson v. Tracy Beltz, Warden; and Keith Ellison, Minn. Atty. Gen., File No. 25-CV-03410 (JMB/DTS)
- Jeffrey M. Bryan
- March 24, 2026
Background
In September 2018, a Sherburne County, Minnesota jury convicted Mark S. Hendrickson of First-Degree Criminal Sexual Conduct under Minn. Stat. § 609.342, subd. 1(a). The trial court sentenced him to 172 months' imprisonment. Hendrickson pursued postconviction relief and a direct appeal in Minnesota state courts. The Minnesota Court of Appeals addressed his case in 2023 and again in 2025, and the Minnesota Supreme Court denied review in 2023.
In August 2025, Hendrickson filed a pro se (self-represented) petition for a writ of habeas corpus — a legal action challenging the lawfulness of his imprisonment — in federal district court under 28 U.S.C. § 2254. He raised ten grounds for relief: (1) constitutionally ineffective assistance of trial counsel; (2) constitutionally ineffective assistance of appellate counsel; (3–8) various additional claims, including defects in the trial court's exercise of jurisdiction; and (9–10) claims that the trial court improperly admitted 'Spriegl evidence,' a Minnesota term for testimony or evidence of prior bad acts offered to show a pattern of conduct.
Magistrate Judge's Report and Recommendation (R&R)
Magistrate Judge David T. Schultz issued an R&R on January 26, 2026. He concluded that nine of the ten grounds were 'procedurally defaulted.' Procedural default occurs when a federal habeas petitioner failed to exhaust state court remedies — meaning he did not fairly present the specific federal constitutional basis of each claim to the appropriate state courts, including the state supreme court — and the state court would now find those claims procedurally barred from further review. Under Coleman v. Thompson, 501 U.S. 722 (1991), a procedurally defaulted claim can only be reviewed in federal court if the petitioner shows (1) cause for the default and actual prejudice from the alleged constitutional violation, or (2) that failure to review the claim would result in a fundamental miscarriage of justice. The Magistrate Judge found Hendrickson had not demonstrated either exception. The tenth ground — improper admission of Spriegl (prior bad acts) evidence — was found to raise only a state evidentiary law question. Under Estelle v. McGuire, 502 U.S. 62 (1991), federal courts do not re-examine state court determinations of state law in habeas proceedings. The Magistrate Judge also recommended denying the motion to expand the record and recommended against issuing a certificate of appealability (a document required before a habeas petitioner can appeal a denial to a higher federal court).
Hendrickson's Objections
Hendrickson objected to the R&R, repeating his claims of ineffective assistance of counsel, jurisdictional defects, and erroneous admission of Spriegl evidence. He also objected to the denial of his motion to expand the record, seeking documents related to a harassment restraining order he had sought against his appellate counsel. He sought review of the Magistrate Judge's earlier (November 24, 2025) denial of his motion to appoint counsel, and he requested a certificate of appealability on six specific grounds.
District Court Analysis
Standard of Review: Dispositive matters (such as dismissal of a habeas petition) are subject to de novo (fresh) review of specific objections, but general or repetitive objections receive only clear-error review. Non-dispositive matters (such as the denial of a motion to appoint counsel) are reversed only if clearly erroneous or contrary to law.
Petition Denial: Judge Bryan found Hendrickson's objections insufficiently specific and lacking well-developed legal argument. The court detected no clear error in the Magistrate Judge's analysis of the ineffective assistance claims (finding failure to fairly present to state courts and failure to demonstrate prejudice to excuse default), the jurisdictional claims (finding failure to fairly present to state courts), and the Spriegl evidence claim (finding it to be a state law matter not cognizable in federal habeas). The petition was denied.
Motion to Expand the Record: Hendrickson sought to add documents from state court proceedings, primarily relating to his harassment restraining order action against his appellate counsel. Judge Bryan found Hendrickson had not explained why these documents were necessary to the constitutional claims in the petition, and therefore could not find clear error in the Magistrate Judge's denial. The motion was denied as moot under the order's terms. (A separate footnote notes that dietary concerns Hendrickson raised in filings were not considered, as they were not raised before the Magistrate Judge and relate to conditions of confinement rather than the validity of conviction or length of sentence, which are the proper subjects of habeas relief.)
Motion to Appoint Counsel: The Magistrate Judge denied the motion to appoint counsel on November 24, 2025. Hendrickson's objection, raised approximately two months later (after the R&R issued), was found to be untimely under Fed. R. Civ. P. 72(a) and D. Minn. L.R. 72.2(a)(1), which require objections to be filed within fourteen days. On the merits, the court also found no clear error or misapplication of law. The denial was affirmed.
Certificate of Appealability: The court declined to issue a certificate of appealability, finding no clear error in the Magistrate Judge's conclusion that reasonable jurists could not disagree with the court's assessment of the constitutional claims. Hendrickson's request for a certificate on six grounds was denied because he offered no argument under the applicable legal standard.
Disposition
Petition denied with prejudice; motion to expand record denied as moot; denial of motion to appoint counsel affirmed; certificate of appealability not issued; remaining motions denied as moot. Judgment to be entered accordingly.
Reviewer note from the AI+
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