Tejeda v. Bureau of Prisons
- Jeffrey Bryan
- 0:24-cv-04343
- U.S. District Court · District of Minnesota
- 2
In Tejeda v. Bureau of Prisons, Judge Bryan denied Jose Luis Tejeda's petition challenging his federal imprisonment and dismissed the case without prejudice.
Federal prisoners who file habeas corpus petitions challenging their custody and whose cases are resolved on an unobjected-to magistrate judge recommendation.
What happened
In Tejeda v. Bureau of Prisons (Case No. 24-CV-04343), Jose Luis Tejeda, representing himself, filed a petition asking a federal court to order his release or other relief from federal imprisonment, a legal procedure known as a petition for a writ of habeas corpus. A magistrate judge reviewed the case and issued a Report and Recommendation on September 19, 2025, advising that the petition be denied. Neither Tejeda nor the Bureau of Prisons objected to that recommendation within the required time.
Because no objections were filed, Judge Jeffrey M. Bryan reviewed the magistrate judge's recommendation only for obvious legal errors — a less rigorous standard than a full review. The court found none.
Judge Bryan adopted the magistrate judge's Report and Recommendation, denied the petition, and dismissed the case without prejudice, meaning Tejeda is not automatically barred from raising these issues again in a future filing.
The detailed version
- Tejeda v. Bureau of Prisons · No. 0:24-cv-04343
- Jeffrey M. Bryan
- Feb. 25, 2026
Background
Jose Luis Tejeda, proceeding without an attorney (self-represented), filed a petition for a writ of habeas corpus — a legal mechanism by which a person in custody challenges the legality of that custody — against the Bureau of Prisons. The case was assigned to United States District Judge Jeffrey M. Bryan, with United States Magistrate Judge Douglas L. Micko handling pre-trial proceedings. The Bureau of Prisons was represented by Ann M. Bildtsen of the United States Attorney's Office in Minneapolis, Minnesota.
Report and Recommendation
On September 19, 2025, Magistrate Judge Micko issued a Report and Recommendation (R&R) recommending that the petition be denied. The opinion does not describe the specific grounds for this recommendation or the substantive legal arguments Tejeda raised in his petition. Neither Tejeda nor the Bureau of Prisons filed objections to the R&R within the time permitted under District of Minnesota Local Rule 72.2(b)(1).
Standard of Review
When no timely objections are filed to a magistrate judge's R&R, the district court reviews the R&R only for clear error. The court cited Federal Rule of Civil Procedure 72(b) and Grinder v. Gammon, 73 F.3d 793, 795 (8th Cir. 1996). Under this deferential standard, the court does not re-examine the merits independently but looks only for obvious legal mistakes.
Ruling
Finding no clear error, Judge Bryan adopted the R&R, denied the petition, and dismissed the action without prejudice. The court's order does not explain the underlying substantive reasons for denial, as it relied on the unobjected-to R&R. Dismissal without prejudice means the case is closed but does not automatically bar Tejeda from attempting to bring a new or amended filing in the future.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.