Dohrman v. Waseca
- Katherine Menendez
- 0:25-cv-04794
- U.S. District Court · District of Minnesota
- 2
In Dohrman v. FCI Waseca, Judge Katherine M. Menendez dismissed without prejudice the petition filed by Jacquelin Dohrman — a federal prisoner challenging conditions at a Minnesota federal prison — because she failed to pay the filing fee or apply for a fee waiver after being given notice to do so.
Federal prisoners, particularly those at FCI Waseca, and any incarcerated person filing pro se (without a lawyer) petitions in the District of Minnesota who must be aware of filing fee requirements and deadlines.
What happened
In Dohrman v. FCI Waseca (No. 25-cv-4794), Jacquelin Dohrman, a woman incarcerated at the Federal Correctional Institution in Waseca, Minnesota, filed a petition on December 29, 2025 asking a federal court to step in because she believed the conditions of her confinement violated her constitutional rights. The day after she filed, the court clerk sent her a letter explaining that she had 15 days to either pay the court's filing fee or submit an application asking to proceed without paying the fee upfront. Ms. Dohrman did neither within that deadline.
Because Ms. Dohrman failed to take either required step, Magistrate Judge Douglas L. Micko issued a Report and Recommendation on January 29, 2026, recommending that the case be dismissed without prejudice — meaning she is not permanently barred from refiling — for failure to prosecute (i.e., failure to move her case forward). Ms. Dohrman did not file any objections to that recommendation.
Judge Katherine M. Menendez reviewed the Magistrate Judge's Report and Recommendation, found no clear error, and accepted it in full. The case was dismissed without prejudice on March 31, 2026, leaving open the possibility that Ms. Dohrman could refile if she addresses the filing fee requirement.
The detailed version
- Dohrman v. Waseca · No. 0:25-cv-04794
- Katherine Menendez
- Mar. 31, 2026
Background
Petitioner Jacquelin Dohrman is a woman incarcerated at the Federal Correctional Institution (FCI) in Waseca, Minnesota. On December 29, 2025, she filed a Petition for a Writ of Habeas Corpus — a legal request asking a court to review whether her imprisonment or its conditions are lawful — alleging that the conditions at FCI Waseca violated her constitutional rights.
The Filing Fee Requirement
The day after filing, the Clerk of Court sent Ms. Dohrman a letter informing her that within 15 days she must either (1) pay the required filing fee, or (2) submit an Application to Proceed Without Prepayment of Fees (commonly called a fee waiver, available to people who cannot afford the fee). The letter warned that failure to do either could result in summary dismissal without prejudice. Ms. Dohrman took neither action.
Magistrate Judge's Report and Recommendation
On January 29, 2026 — well after the 15-day deadline — United States Magistrate Judge Douglas L. Micko issued a Report and Recommendation (R&R) recommending dismissal without prejudice under Federal Rule of Civil Procedure 41(b), which authorizes a court to dismiss a case when a plaintiff or petitioner fails to prosecute it (i.e., fails to take the steps necessary to move the case forward). Ms. Dohrman filed no objections to the R&R.
Standard of Review
When a party does not object to a magistrate judge's R&R, the district court reviews it only for clear error. See Nur v. Olmsted County, 563 F. Supp. 3d 946, 949 (D. Minn. 2021) (citing Fed. R. Civ. P. 72(b); Grinder v. Gammon, 73 F.3d 793, 795 (8th Cir. 1996)). This is a more deferential standard than the de novo (fresh, independent) review that applies when objections are filed.
Ruling
Judge Menendez found no clear error in Magistrate Judge Micko's R&R and adopted it in full. The case was dismissed without prejudice under Rule 41(b). A dismissal without prejudice means Ms. Dohrman is not permanently barred from refiling; she may be able to bring a new petition if she satisfies the filing fee requirements or obtains a fee waiver.
What This Means Practically
The court did not reach the merits of Ms. Dohrman's constitutional claims about conditions at FCI Waseca. The dismissal was based solely on her failure to comply with the court's administrative fee requirement after receiving notice.
Reviewer note from the AI+
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.