Jonathan Richard Lee v. State of Minnesota
- Jeffrey Bryan
- 0:26-cv-01785
- U.S. District Court · District of Minnesota
- 2
In Lee v. State of Minnesota, Judge Jeffrey M. Bryan denied Jonathan Richard Lee's petition for a writ of habeas corpus (a court order challenging a person's imprisonment), dismissed the case, and declined to allow an appeal, after finding no clear error in the magistrate judge's recommendation.
Self-represented individuals in Minnesota (and the broader Eighth Circuit) who file federal habeas corpus petitions challenging state-court convictions or custody. The ruling also illustrates the procedural consequence of failing to object to a magistrate judge's Report and Recommendation — triggering only clear-error review — which affects any litigant in federal court who does not timely object.
What happened
In Lee v. State of Minnesota (Case No. 26-CV-1785), Jonathan Richard Lee, representing himself, filed a federal habeas corpus petition — a legal request asking a federal court to review whether his imprisonment is lawful — against the State of Minnesota. He also applied to proceed without paying court fees (known as proceeding in forma pauperis). The case was referred to Magistrate Judge John F. Docherty, who issued a Report and Recommendation on March 16, 2026, recommending that both the petition and the fee waiver request be denied, and that the case be dismissed without issuing a certificate of appealability (a required permission slip to appeal a habeas ruling to a higher court).
Neither Lee nor the State of Minnesota filed any objections to the magistrate judge's recommendation within the allowed time period. When no objections are filed, the district court applies a lower level of review, looking only for clear errors in the recommendation rather than reviewing the issues from scratch.
Judge Jeffrey M. Bryan reviewed the Report and Recommendation, found no clear error, and adopted it in full. The court denied the habeas petition, denied the fee waiver application as moot (meaning there was no longer any need to decide it), dismissed the case, and declined to issue a certificate of appealability, which means Lee would need to separately seek permission from an appeals court to continue challenging the ruling.
The detailed version
- Jonathan Richard Lee v. State of Minnesota · No. 0:26-cv-01785
- Jeffrey M. Bryan
- Apr. 1, 2026
Background
Jonathan Richard Lee, a self-represented petitioner residing in Sartell, Minnesota, filed a petition for a writ of habeas corpus in the United States District Court for the District of Minnesota. A habeas corpus petition is a legal mechanism by which a person in custody challenges the legality of that custody in federal court. Lee simultaneously filed an application to proceed in forma pauperis (IFP), which is a request to waive court filing fees due to financial hardship. The respondent is the State of Minnesota, represented by the Minnesota Attorney General's Office and the Stearns County Attorney's Office.
Magistrate Judge's Report and Recommendation
The matter was referred to United States Magistrate Judge John F. Docherty, who issued a Report and Recommendation (R&R) on March 16, 2026. The R&R recommended that: (1) the habeas petition be denied; (2) the IFP application be denied; (3) the action be dismissed; and (4) the Court decline to issue a certificate of appealability (COA). A COA is a procedural prerequisite — a permission slip — that a habeas petitioner must obtain before appealing a district court's denial of a habeas petition to the Eighth Circuit Court of Appeals. Without a COA, the petitioner cannot pursue a direct appeal of right.
The opinion does not describe the underlying facts or legal grounds of Lee's habeas petition, nor does it set forth the magistrate judge's reasoning in recommending denial. The summary here is therefore limited to what the district court's order discloses.
Standard of Review
Neither Lee nor the State of Minnesota filed objections to the R&R within the time allowed under District of Minnesota Local Rule 72.2(b)(1). When no timely objections are filed to a magistrate judge's R&R, the district court reviews the R&R only for clear error, rather than conducting a de novo (fresh, independent) review. The Court cited Federal Rule of Civil Procedure 72(b) and Grinder v. Gammon, 73 F.3d 793, 795 (8th Cir. 1996) as authority for this standard.
Ruling
Judge Bryan found no clear error in the R&R and adopted it in full. The Court issued the following orders:
- The R&R is adopted.
- The habeas petition is denied.
- The IFP application is denied as moot — meaning that because the case is being dismissed, there is no longer any practical need to rule on whether Lee qualifies for the fee waiver.
- The action is dismissed.
- No certificate of appealability will issue.
Implications for the Petitioner
Because the Court declined to issue a certificate of appealability, Lee cannot appeal this ruling to the Eighth Circuit as a matter of right under the standard habeas appellate process. He would need to separately request a COA from the Eighth Circuit itself. The opinion does not address any other post-judgment remedies that may or may not be available to Lee.
Reviewer note from the AI+
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.