Campbell v. State of Minnesota
- Nancy Brasel
- 0:24-cv-01788
- U.S. District Court · District of Minnesota
- 2
In Campbell v. State of Minnesota, Judge Brasel denied Clifton Scott Campbell's petition challenging his state conviction and dismissed the case with prejudice.
Individuals convicted in Minnesota state court who seek federal review of their conviction or sentence under 28 U.S.C. § 2254. The denial with prejudice and refusal to issue a certificate of appealability directly affect Clifton Scott Campbell's ability to continue challenging his state conviction in federal court.
What happened
In Clifton Scott Campbell v. State of Minnesota (Case No. 24-CV-1788), Clifton Scott Campbell filed a federal petition asking a court to review and overturn his state-court conviction or sentence, a legal procedure that allows federal courts to examine whether a person is being held in violation of federal law or the Constitution. The petition was referred to a magistrate judge — a lower-level federal judicial officer who assists district court judges — who issued a Report and Recommendation on August 20, 2025, concluding that the petition should be denied. Because neither Campbell nor the State of Minnesota objected to that recommendation, the district court reviewed it only for obvious mistakes.
Finding no clear error in the magistrate judge's analysis, the court accepted the recommendation in full. The court denied Campbell's petition and dismissed the case with prejudice, meaning Campbell cannot refile the same petition in this court.
Judge Nancy E. Brasel of the United States District Court for the District of Minnesota issued this order on October 6, 2025. The court also declined to issue a certificate of appealability, which is a required permission slip that a petitioner must obtain before appealing the denial of this type of petition to a higher court. Without that certificate, Campbell faces a procedural barrier to pursuing an appeal.
The detailed version
- Campbell v. State of Minnesota · No. 0:24-cv-01788
- Nancy Brasel
- Oct. 6, 2025
Background
Clifton Scott Campbell filed a Petition for Writ of Habeas Corpus under 28 U.S.C. § 2254 — a federal statute that allows a person held in state custody to ask a federal court to review whether the detention violates the U.S. Constitution or federal law. The respondent is the State of Minnesota.
Magistrate Judge Proceedings
The matter was referred to United States Magistrate Judge Douglas L. Micko, who issued a Report and Recommendation on August 20, 2025. The opinion does not describe the substance of Magistrate Judge Micko's analysis or the grounds on which he recommended denial. Neither Campbell nor the State of Minnesota filed objections to the Report and Recommendation.
Standard of Review
Because no party objected, District Judge Brasel reviewed the Report and Recommendation only for clear error, consistent with Federal Rule of Civil Procedure 72(b) and the Eighth Circuit's holding in Grinder v. Gammon, 73 F.3d 793, 795 (8th Cir. 1996) (per curiam). The court found no clear error.
Disposition
Judge Brasel accepted the Report and Recommendation and entered the following orders:
- The Report and Recommendation is accepted.
- The § 2254 petition is denied.
- The action is dismissed with prejudice.
- No certificate of appealability (COA) is issued. A COA is required under 28 U.S.C. § 2253(c) before a habeas petitioner may appeal a denial to the circuit court. The court's refusal to issue a COA means Campbell must separately seek permission from the Eighth Circuit Court of Appeals to proceed with any appeal.
What the Opinion Does Not Address
The order itself does not set out the factual background of Campbell's underlying state conviction, the legal claims raised in the petition, or the magistrate judge's reasons for recommending denial. Those details would appear in the referenced Report and Recommendation (ECF No. 21), which is not reproduced here.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.