Jonathan Richard Lee v. State of Minnesota
- John Docherty
- 0:26-cv-01785
- U.S. District Court · District of Minnesota
- 5
In Jonathan Richard Lee v. State of Minnesota, Magistrate Judge Docherty recommended denying habeas relief, dismissing the case, denying fee relief, and withholding an appeal certificate.
Jonathan Richard Lee and his three ongoing Minnesota state-court criminal prosecutions; the State of Minnesota is the respondent.
What happened
In Jonathan Richard Lee v. State of Minnesota, Jonathan Richard Lee asked the federal court to stop or review three ongoing Minnesota criminal prosecutions involving alleged restraining-order violations and obstruction of legal process. He argued that his conduct did not violate state law and that his constitutional rights were violated.
The court said Lee generally must present his constitutional claims first in the state courts and complete the state appeals process before seeking federal habeas relief. Although double-jeopardy claims can sometimes be raised earlier, the court said Lee did not provide enough facts to support that claim.
Magistrate Judge John F. Docherty recommended denying the habeas petition and dismissing the case. He also recommended denying Lee’s application to proceed without paying filing fees and not granting a certificate required to appeal a final state-related habeas decision. The recommendation is not itself a final order, and the notice says objections may be filed within 14 days after service.
The detailed version
- Jonathan Richard Lee v. State of Minnesota · No. 0:26-cv-01785
- John F. Docherty
- Mar. 16, 2026
Background
Jonathan Richard Lee is being prosecuted in three separate Minnesota state-court criminal proceedings. The charges involve alleged violations of a restraining order and, in one proceeding, alleged obstruction of legal process. Lee filed a federal petition seeking a writ of habeas corpus, which is a court order addressing allegedly unlawful custody or detention. He challenged the prosecutions on the grounds that his conduct did not violate state law and that his constitutional rights had been violated.
Because Lee was not in custody under a state-court judgment, the court treated his petition as arising under 28 U.S.C. § 2241 rather than § 2254. The court nevertheless applied the preliminary review rules used for habeas petitions. Those rules require dismissal when the petition plainly shows that the petitioner is not entitled to relief.
Court’s Analysis
The court explained that federal courts generally require people facing state criminal charges to present their constitutional claims in the state courts before seeking federal habeas relief. This requirement is based on respect for state courts and the federal system. It ordinarily requires the state criminal case to reach judgment and the petitioner to pursue available state appellate review.
The court concluded that Lee’s challenges to whether he committed the charged offenses, whether he should have received warnings under Miranda v. Arizona, and whether the prosecutions violated his constitutional rights did not qualify for an exception to that requirement. Lee could raise those arguments in the state trial court and, if convicted, seek review in the Minnesota appellate courts.
The court separately considered Lee’s reference to double jeopardy and the Blockburger test. It stated that double-jeopardy claims can be an exception to the usual requirement that a state prosecution reach judgment first. However, the court concluded that Lee’s petition did not provide factual allegations showing how any of the ongoing prosecutions placed him in double jeopardy. The court therefore determined that this claim could not proceed. It also noted that Lee’s assertion that a message was too cursory or innocuous to violate a restraining order concerned whether the alleged conduct supported criminal charges, not double jeopardy.
Recommended Disposition
The report and recommendation recommends that Lee’s habeas petition be denied and that the matter be dismissed. It also recommends that his application to proceed without paying filing fees be denied and that he not receive a certificate of appealability, which is required for an appeal from a final state-related habeas decision. The magistrate judge stated that this report and recommendation is not a final order or judgment and is not directly appealable. The notice allows specific written objections within 14 days after service, with a response allowed within 14 days after service of the objections.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.