Dohrman v. Waseca
- Katherine Menendez
- 0:25-cv-04794
- U.S. District Court · District of Minnesota
- 2
In Dohrman v. FCI Waseca, Judge Menendez dismissed without prejudice a prisoner's petition challenging conditions at a federal correctional institution because she failed to pay the filing fee or apply to waive it.
People incarcerated in federal facilities who file court petitions challenging their conditions of confinement, particularly those who may be unaware of or unable to meet filing fee payment or waiver requirements.
What happened
In Dohrman v. FCI Waseca (No. 25-cv-4794), Jacquelin Dohrman, who is incarcerated at the Federal Correctional Institution in Waseca, filed a petition asking a federal court to order relief based on her claim that conditions at the facility violated her constitutional rights. The day after she filed, the court's clerk notified her that she had 15 days to either pay the filing fee or apply to have it waived — and warned that failing to do so could result in dismissal. She did neither within that window.
A United States Magistrate Judge reviewed the situation and issued a Report and Recommendation concluding that the case should be dismissed for failure to prosecute — meaning Ms. Dohrman had not taken the steps necessary to move her case forward. She did not file any objections to that recommendation.
Judge Katherine M. Menendez reviewed the Magistrate Judge's Report and Recommendation, found no clear error, and adopted it. The court dismissed the case without prejudice, meaning Ms. Dohrman is not permanently barred from refiling her claims.
The detailed version
- Dohrman v. Waseca · No. 0:25-cv-04794
- Katherine Menendez
- Mar. 31, 2026
Background
On December 29, 2025, Petitioner Jacquelin Dohrman filed a petition for a writ of habeas corpus — a legal request asking a court to review the lawfulness of a person's confinement or conditions of confinement — against FCI Waseca, the Federal Correctional Institution where she is held. She alleged that conditions at the facility violated her constitutional rights.
Procedural History
The day after filing, the Clerk of Court sent Ms. Dohrman a letter notifying her that she was required, within 15 days, to either pay the applicable filing fee or submit an Application to Proceed Without Prepayment of Fees (commonly known as an in forma pauperis application, which allows qualifying litigants to avoid upfront court costs). The letter warned that failure to do either could result in the case being summarily dismissed without prejudice.
Ms. Dohrman did not comply with either requirement within the deadline. On January 29, 2026 — after the 15-day window had closed — United States Magistrate Judge Douglas L. Micko issued a Report and Recommendation (R&R) recommending that the action be dismissed without prejudice pursuant to Rule 41(b) of the Federal Rules of Civil Procedure. Rule 41(b) authorizes a court to dismiss an action if the plaintiff fails to prosecute — that is, fails to take necessary steps to advance the case. Ms. Dohrman filed no objections to the R&R.
Legal Standard
When a party does not object to a Magistrate Judge's Report and Recommendation, the district court reviews it only for clear error. The court cited Nur v. Olmsted County, 563 F. Supp. 3d 946, 949 (D. Minn. 2021), which in turn cited Federal Rule of Civil Procedure 72(b) and Grinder v. Gammon, 73 F.3d 793, 795 (8th Cir. 1996), as authority for this standard.
Ruling
Judge Menendez found no clear error in the Magistrate Judge's R&R and adopted it. The court dismissed the case without prejudice under Rule 41(b). A dismissal without prejudice does not bar Ms. Dohrman from refiling her claims, though any refiling would be subject to applicable procedural requirements including payment of fees or a proper application to waive them.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.