Andersen v. Stenseth
Travis Clay Andersen v. Lisa Stenseth, MCF-RC Warden, and Paul Schnell, MN DOC Commissioner
- Jeffrey Bryan
- 0:26-cv-02845
- U.S. District Court · District of Minnesota
- 2
In Andersen v. Stenseth, Judge Bryan denied Travis Clay Andersen's petition for release from state custody, finding no clear error in the magistrate judge's recommendation.
State prisoners in Minnesota who file federal habeas petitions challenging their custody and who fail to object to a magistrate judge's unfavorable recommendation, as such inaction limits the district court's review to clear error only.
What happened
In Andersen v. Stenseth (Case No. 26-CV-2845), Travis Clay Andersen, a self-represented prisoner held in Rush City, Minnesota, filed a federal petition seeking relief from his state custody — a legal challenge asking a federal court to review whether his continued imprisonment is lawful. The case was first reviewed by Magistrate Judge Leo I. Brisbois, who issued a Report and Recommendation on June 5, 2026, concluding that the petition should be denied and that Andersen should not be granted a certificate of appealability — a document required before a prisoner can appeal such a denial to a higher court.
Neither Andersen nor the respondents — MCF-RC Warden Lisa Stenseth and Minnesota Department of Corrections Commissioner Paul Schnell — filed any objections to the magistrate judge's recommendation within the allowed time period. Because no objections were filed, the court was only required to review the recommendation for obvious mistakes.
Judge Jeffrey M. Bryan found no clear error in the magistrate judge's recommendation and issued an order on June 22, 2026, adopting the Report and Recommendation, denying the petition, and declining to issue a certificate of appealability. Without a certificate of appealability, Andersen would need to separately seek permission from an appeals court before he could pursue a further appeal.
The detailed version
- Andersen v. Stenseth · No. 0:26-cv-02845
- Jeffrey M. Bryan
- June 22, 2026
Background
Petitioner Travis Clay Andersen, proceeding self-represented from Rush City, Minnesota, filed a federal habeas corpus petition — a legal request asking a federal court to determine whether a person's imprisonment is lawful — challenging his state custody. The respondents are Lisa Stenseth, identified as the MCF-RC Warden, and Paul Schnell, identified as the Minnesota Department of Corrections Commissioner, both represented by the Office of the Minnesota Attorney General.
Magistrate Judge's Report and Recommendation
The matter was referred to United States Magistrate Judge Leo I. Brisbois, who issued a Report and Recommendation (R&R) dated June 5, 2026. The R&R recommended that Andersen's habeas petition be denied and that no certificate of appealability (COA) be issued. A COA is a prerequisite for a habeas petitioner to appeal a denial to a higher court; without it, the petitioner must seek permission from the appellate court separately before an appeal may proceed.
Review Standard
Neither party filed objections to the R&R within the time period established by District of Minnesota Local Rule 72.2(b)(1). In the absence of timely objections, the district court's standard of review is limited to screening for "clear error" under Federal Rule of Civil Procedure 72(b), citing Grinder v. Gammon, 73 F.3d 793, 795 (8th Cir. 1996). This is a deferential standard that does not require the district court to independently re-examine the merits of the underlying claims.
Ruling
Judge Bryan found no clear error in the R&R. Accordingly, the court:
- Adopted the R&R (Doc. No. 2).
- Denied the habeas petition (Doc. No. 1).
- Declined to issue a certificate of appealability.
The opinion does not describe the underlying facts of Andersen's state conviction or the specific legal arguments raised in the habeas petition, as those details were addressed in the R&R rather than in this order. The court directed that judgment be entered accordingly.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.