Michel v. Rardin
- Nancy Brasel
- 0:25-cv-03547
- U.S. District Court · District of Minnesota
- 2
In Michel v. Rardin, Judge Brasel denied Kenyatta Michel's petition challenging his federal imprisonment and dismissed the case with prejudice.
Federal prisoners held at FMC Rochester or other federal facilities who may be considering filing habeas corpus petitions challenging the legality of their detention in the District of Minnesota.
What happened
In Michel v. Rardin (Case No. 25-CV-3547), federal prisoner Kenyatta Michel filed a petition for a writ of habeas corpus — a legal request asking the court to order his release or challenge the legality of his detention — against Jared Rardin, the warden of FMC Rochester, a federal medical center in Minnesota. Michel also asked to proceed without paying court fees. A magistrate judge (a lower-level federal judicial officer who assists district court judges) issued a Report and Recommendation on October 1, 2025, recommending that the petition be denied.
No party filed any objection to the magistrate judge's Report and Recommendation. When no objections are filed, the district court reviews the report only for 'clear error' — a more limited review than it would otherwise conduct. The court found no clear error in the magistrate judge's analysis.
Judge Nancy E. Brasel accepted the Report and Recommendation, denied Michel's habeas petition, and dismissed the entire case with prejudice — meaning Michel cannot refile this same claim in this court. Michel's separate request to proceed without paying filing fees was denied as moot, meaning it no longer needed to be decided because the case itself was dismissed.
The detailed version
- Michel v. Rardin · No. 0:25-cv-03547
- Nancy Brasel
- Nov. 10, 2025
Background
Petitioner Kenyatta Michel filed a petition for a writ of habeas corpus against Jared Rardin, identified as the warden of FMC Rochester (a federal medical center in Rochester, Minnesota). A habeas corpus petition is a legal challenge to the lawfulness of one's detention, asking a court to order release or other relief. Michel also filed an application to proceed in forma pauperis (IFP) — a request to waive the filing fee based on inability to pay.
Magistrate Judge's Report and Recommendation
United States Magistrate Judge Elizabeth Cowan Wright issued a Report and Recommendation (R&R) on October 1, 2025, recommending that the habeas petition be denied. The opinion before the district court does not reproduce the substance of the R&R's analysis; it references only that the R&R existed and that no party objected to it.
Standard of Review
Because no party filed objections to the R&R, Judge Brasel applied a 'clear error' standard of review under Federal Rule of Civil Procedure 72(b) and the Eighth Circuit's decision in Grinder v. Gammon, 73 F.3d 793, 795 (8th Cir. 1996) (per curiam). This is a deferential standard: the district court will not disturb a magistrate judge's recommendation unless it contains a plain or obvious error.
Ruling
Finding no clear error, Judge Brasel:
- Accepted the magistrate judge's Report and Recommendation;
- Denied the Petition for Writ of Habeas Corpus;
- Dismissed the action with prejudice — barring Michel from refiling this same claim in this court; and
- Denied Michel's IFP application as moot, because the dismissal of the case eliminated any need to resolve the fee-waiver request.
Judgment was ordered to be entered accordingly.
Notes on Opinion Scope
The district court's order does not summarize the underlying legal reasoning from the R&R — it only confirms acceptance after finding no clear error. The substantive basis for denying the habeas petition (e.g., procedural default, failure to exhaust, merits denial, or other ground) is not set forth in this order and cannot be determined from the text provided.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.