Hendrickson v. Beltz
- Jeffrey Bryan
- 0:25-cv-03410
- U.S. District Court · District of Minnesota
- 8
In Hendrickson v. Beltz, Judge Bryan denied Mark S. Hendrickson's petition for federal court relief from his Minnesota criminal sexual conduct conviction, finding his claims were not properly raised in state court first.
State prisoners in Minnesota (and elsewhere in the Eighth Circuit) who seek federal habeas corpus review of their convictions: this order illustrates that failing to properly raise federal constitutional claims in state court proceedings before filing a federal habeas petition will result in those claims being found procedurally defaulted and barred from federal review.
What happened
In Hendrickson v. Beltz, Mark S. Hendrickson, a Minnesota state prisoner convicted of First-Degree Criminal Sexual Conduct in 2018 and sentenced to 172 months in prison, asked a federal court to overturn his conviction. He raised ten grounds for relief, including claims that his trial and appellate lawyers were constitutionally ineffective, that the trial court lacked proper authority to hear his case, and that the trial court wrongly allowed certain evidence of prior bad acts to be presented to the jury.
A federal magistrate judge reviewed the petition and issued a recommendation that it be denied. The magistrate judge found that nine of Hendrickson's ten claims were procedurally defaulted — meaning he had failed to properly raise them in Minnesota state courts before bringing them to federal court — and that the tenth claim involved a question of state evidence law that federal courts cannot review in this type of proceeding. The magistrate judge also recommended denying Hendrickson's motion to expand the record with additional documents and his motion for a preliminary injunction, and recommended that no certificate of appealability (a document needed to pursue a further appeal) be issued.
Judge Jeffrey M. Bryan overruled Hendrickson's objections to the magistrate judge's recommendations, finding them insufficiently specific or legally supported. Judge Bryan denied the petition, affirmed the earlier denial of Hendrickson's motion to appoint a lawyer, denied as moot Hendrickson's remaining motions, and declined to issue a certificate of appealability.
The detailed version
- Hendrickson v. Beltz · No. 0:25-cv-03410
- Jeffrey M. Bryan
- Mar. 24, 2026
Background
In September 2018, a jury in Sherburne County, Minnesota, found Mark S. Hendrickson guilty of First-Degree Criminal Sexual Conduct under Minnesota Statute § 609.342, subd. 1(a). The trial court sentenced him to 172 months' imprisonment. Hendrickson subsequently sought postconviction relief and pursued a direct appeal in the Minnesota Court of Appeals.
In August 2025, Hendrickson — representing himself — filed a petition for a writ of habeas corpus (a federal court challenge to the legality of his imprisonment) under 28 U.S.C. § 2254 in the United States District Court for the District of Minnesota. He asserted ten grounds for relief: claims of constitutionally ineffective assistance of both trial and appellate counsel, alleged defects in the state trial court's jurisdiction, and improper admission of so-called "Spriegl" evidence (Minnesota's term for prior bad acts evidence admitted under specific rules) at trial.
Magistrate Judge's Report and Recommendation
United States Magistrate Judge David T. Schultz issued a Report and Recommendation (R&R) on January 26, 2026. The Magistrate Judge concluded that:
- Nine of the ten grounds were procedurally defaulted — Hendrickson had failed to fairly present these claims to the appropriate Minnesota state courts before bringing them to federal court, and the state courts would now bar him from raising them.
- Hendrickson had not demonstrated "cause and prejudice" or a "fundamental miscarriage of justice" sufficient to excuse the procedural defaults, as required under Coleman v. Thompson, 501 U.S. 722 (1991).
- The remaining ground — challenging the admission of Spriegl evidence — raised a question of state evidentiary law, which federal habeas courts do not review under Estelle v. McGuire, 502 U.S. 62 (1991).
- Hendrickson's motion to expand the record with additional state court documents should be denied.
- All other pending motions should be denied as moot.
- No certificate of appealability (a document required before a prisoner can appeal a federal habeas denial) should issue.
Hendrickson filed objections to the R&R; Respondents filed a response.
Standard of Review
For dispositive matters (such as whether to grant or deny the habeas petition), the district court reviews a magistrate judge's recommendation de novo (independently) as to any portion specifically objected to, but applies a clear-error standard to objections that merely repeat arguments already considered by the magistrate judge. For non-dispositive matters (such as the motion to appoint counsel and the motion to expand the record), the district court reviews the magistrate judge's order only for clear error or error contrary to law — a highly deferential standard. The court applies liberal construction to submissions from self-represented litigants.
Analysis
Habeas Petition — Procedural Default
Federal habeas relief under 28 U.S.C. § 2254 requires that a state prisoner first exhaust state court remedies by fairly presenting each federal claim to the appropriate state courts, including any state supreme court with discretionary review authority. A claim is procedurally defaulted if the prisoner failed to exhaust state remedies and the state courts would now bar the claim. A federal court cannot review a procedurally defaulted claim unless the petitioner shows (1) cause for the default and actual prejudice, or (2) that failure to review the claim would result in a fundamental miscarriage of justice.
Judge Bryan found that Hendrickson's objections were not specific enough to warrant de novo review and showed no clear error in the Magistrate Judge's analysis. Hendrickson made only conclusory assertions about ineffective assistance, jurisdictional defects, and the Spriegl evidence, without addressing the Magistrate Judge's specific conclusions that he had failed to fairly present his claims to the state courts or to demonstrate the prejudice needed to excuse the defaults.
Motion to Expand the Record
After briefing closed, Hendrickson moved to expand the record with state court documents, including materials related to a harassment restraining order he sought against his appellate counsel. The Magistrate Judge denied this motion. Hendrickson objected but did not explain why those documents were necessary to the constitutional claims in his petition. Judge Bryan found no clear error in the Magistrate Judge's denial.
Motion to Appoint Counsel
The Magistrate Judge had denied Hendrickson's motion to appoint counsel on November 24, 2025. Under Federal Rule of Civil Procedure 72(a) and Local Rule 72.2(a)(1), objections to a magistrate judge's non-dispositive orders must be filed within fourteen days. Hendrickson raised his objection approximately two months later, making it untimely. Judge Bryan also found, independently, that Hendrickson had not advanced sufficient argument to show the denial was clearly erroneous or contrary to law, and affirmed the denial.
Certificate of Appealability
A certificate of appealability is required before a federal prisoner can appeal the denial of a habeas petition. The standard is whether reasonable jurists could disagree with the court's assessment of the constitutional claims. Hendrickson requested such a certificate on six grounds but made no argument under the applicable legal standard. Judge Bryan found no clear error in the Magistrate Judge's analysis and declined to issue the certificate.
Dietary Concerns
In a footnote, Judge Bryan declined to address what appeared to be a request regarding Hendrickson's diet while in custody, noting the issue had not been raised before the Magistrate Judge and that dietary conditions of confinement fall outside the scope of habeas corpus relief, which is limited to challenges to the validity of a conviction or the length of detention.
Disposition
Judge Bryan: (1) overruled Hendrickson's objection to the R&R; (2) adopted the R&R; (3) denied the petition; (4) affirmed the denial of the motion to appoint counsel; (5) denied as moot Hendrickson's remaining motions; and (6) declined to issue a certificate of appealability.
Read the full 8-page opinion on CourtListener, the free public archive maintained by the Free Law Project.