Jonathan Richard Lee v. State of Minnesota
- Jeffrey Bryan
- 0:26-cv-01785
- U.S. District Court · District of Minnesota
- 2
In Lee v. State of Minnesota, Judge Bryan denied Jonathan Richard Lee's petition for federal court review of his state conviction and dismissed the case.
People who are in state custody and considering filing a federal habeas petition to challenge the legality of their confinement, particularly self-represented petitioners in the District of Minnesota.
What happened
In Jonathan Richard Lee v. State of Minnesota (Case No. 26-CV-1785), Jonathan Richard Lee, representing himself, filed a petition asking a federal court to review his state-level detention or conviction — a process known as a habeas petition, which allows people held by the government to challenge the lawfulness of their confinement. A magistrate judge reviewed the petition and issued a report recommending that the petition be denied and the case be dismissed.
Neither Lee nor the State of Minnesota objected to the magistrate judge's report within the allowed time. When no party objects, the district court reviews the report only for obvious legal errors — a lower standard than a full independent review.
Judge Jeffrey M. Bryan found no clear error in the magistrate judge's report, adopted it, and denied the habeas petition. The court also denied Lee's request to proceed without paying court fees as moot (meaning the fee request no longer needed to be decided since the case was being dismissed anyway), dismissed the action, and declined to issue a certificate of appealability — a document that would have been required for Lee to appeal the dismissal to a higher court.
The detailed version
- Jonathan Richard Lee v. State of Minnesota · No. 0:26-cv-01785
- Jeffrey M. Bryan
- Apr. 1, 2026
Background
Petitioner Jonathan Richard Lee, representing himself and residing in Sartell, MN, filed a petition for a writ of habeas corpus — a legal mechanism by which a person in government custody can ask a federal court to examine whether their detention or conviction is lawful. He also applied to proceed in forma pauperis, meaning he sought permission to litigate without paying the standard court filing fees due to claimed financial hardship.
Magistrate Judge's Report and Recommendation
United States Magistrate Judge John F. Docherty issued a Report and Recommendation (R&R) dated March 16, 2026, recommending that: (1) the habeas petition be denied; (2) the application to proceed without paying fees be denied; (3) the action be dismissed; and (4) no certificate of appealability be issued. A certificate of appealability is a threshold requirement in habeas cases — without it, a petitioner cannot appeal to a higher court.
No Objections Filed
Neither Lee nor the State of Minnesota filed objections to the R&R within the time allowed under Local Rule 72.2(b)(1). When no timely objections are filed, the district court applies a "clear error" standard of review — a deferential standard under which the court affirms the magistrate judge's recommendations unless they contain an obvious legal mistake.
Court's Ruling
Judge Jeffrey M. Bryan found no clear error in the R&R and adopted it in full. The court issued the following dispositions:
- The R&R was adopted.
- The habeas petition was denied.
- The application to proceed without paying fees was denied as moot — meaning that because the petition was denied and the case dismissed, the fee application no longer had any practical effect requiring a ruling on the merits.
- The action was dismissed.
- The court declined to issue a certificate of appealability, which means Lee faces a procedural barrier to appealing this decision to a higher federal court.
Notes on the Opinion
The opinion does not describe the underlying facts of Lee's state-level case, the nature of his conviction or confinement, or the specific legal grounds on which the magistrate judge recommended denial. Because the R&R itself is not reproduced in this order, those details are not available from this document alone.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.