Spottswood v. Washington County MN Probation

Background

Shawn Clarke Spottswood filed a petition under 28 U.S.C. § 2254, the federal law that allows a person in state custody to seek federal habeas review. On August 7, 2025, the court ordered Spottswood to show why the case should not be dismissed for failure to exhaust state-court remedies. Exhaustion generally requires presenting the relevant claims through the available state-court process before seeking federal habeas relief.

The order warned that failure to respond could lead to a recommendation of dismissal. Spottswood did not submit the required response. The report and recommendation therefore relied on the reasons stated in the earlier order.

Recommended Disposition

Judge Elizabeth Cowan Wright recommended that Spottswood’s § 2254 petition be denied for failure to exhaust state-court remedies and that the action be dismissed. The judge also recommended that Spottswood’s application to proceed without prepaying filing fees or costs be denied as moot.

The judge further recommended that no certificate of appealability be issued. A certificate of appealability is required for a § 2254 petitioner to appeal an adverse ruling. Because the recommended dismissal was procedural, the report stated that a certificate would be appropriate only if reasonable judges could debate whether the procedural ruling was correct; it concluded that no reasonable court would disagree.

Procedural Status

The document is a magistrate judge’s report and recommendation, not a final district-court order or judgment. The notice states that it is not directly appealable to the U.S. Court of Appeals for the Eighth Circuit and that specific written objections could be filed within 14 days after service.