Chapman v. United States Federal Bureau of Prisons
- Eric Tostrud
- 0:25-cv-03358
- U.S. District Court · District of Minnesota
- 1
In Chapman v. Federal Bureau of Prisons, Judge Tostrud denied Mindy L. Chapman's petition for court-ordered release and dismissed the case without prejudice.
Federal prisoners who file habeas corpus petitions — particularly those whose petitions are reviewed by a magistrate judge — may be affected by the procedural outcome here, specifically the dismissal without prejudice following an uncontested Report and Recommendation.
What happened
In Chapman v. United States Federal Bureau of Prisons (File No. 25-cv-3358), Mindy L. Chapman filed a petition asking a federal court to order her release from federal prison custody — a legal procedure that allows a person to challenge the lawfulness of their imprisonment. A magistrate judge, Douglas L. Micko, reviewed the petition and issued a Report and Recommendation on September 26, 2025, recommending that it be denied. No party objected to that recommendation.
Because no objections were filed, the presiding district judge reviewed the magistrate judge's report only for clear error — a limited standard of review. The court found no clear error in the magistrate judge's analysis or recommendations.
Judge Eric C. Tostrud accepted the Report and Recommendation, denied Chapman's petition, and dismissed the action without prejudice, meaning Chapman is not permanently barred from filing again. Judgment was ordered to be entered accordingly.
The detailed version
- Chapman v. United States Federal Bureau of Prisons · No. 0:25-cv-03358
- Eric Tostrud
- Oct. 24, 2025
Background
Petitioner Mindy L. Chapman filed a petition for a writ of habeas corpus — a legal mechanism by which a person in custody can ask a federal court to examine whether their imprisonment is lawful — against the United States Federal Bureau of Prisons as respondent. The case was filed in the United States District Court for the District of Minnesota.
Magistrate Judge's Report and Recommendation
Magistrate Judge Douglas L. Micko issued a Report and Recommendation (R&R) on September 26, 2025, at ECF No. 5, recommending denial of the petition. The opinion does not describe the substance of the R&R's reasoning. No party — neither Chapman nor the Bureau of Prisons — filed objections to the R&R within the allotted time.
Standard of Review
When no party objects to a magistrate judge's R&R, the district court reviews it only for "clear error" under Federal Rule of Civil Procedure 72(b). This is a deferential standard, meaning the court will accept the R&R unless it identifies a plain mistake. Judge Tostrud cited Grinder v. Gammon, 73 F.3d 793, 795 (8th Cir. 1996) (per curiam) as authority for this standard.
Ruling
Finding no clear error, Judge Tostrud issued the following orders:
- Accepted the R&R (ECF No. 5).
- Denied Chapman's petition for a writ of habeas corpus (ECF No. 1).
- Dismissed the action without prejudice.
The court directed that judgment be entered accordingly.
Note on Scope of This Order
This order is brief and adopts the magistrate judge's R&R by reference. The underlying legal basis for the recommended denial — for example, whether the petition failed on jurisdictional, procedural, or substantive grounds — is contained in the R&R itself (ECF No. 5), which is not reproduced in this opinion.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.