Wren v. Bollin
James D. Wren v. William Bollin, Warden, in his official capacity; Gary, Sargeant, in his official and individual capacities; Terra O’Conner, Lieutenant, in her official and individual capacities
- Jeffrey Bryan
- 0:25-cv-03623
- U.S. District Court · District of Minnesota
- 2
Counsel of record per CourtListener. Firm names are approximate.
In Wren v. Bollin, Judge Bryan denied prisoner James D. Wren's motion for a preliminary injunction after adopting a magistrate judge's recommendation finding no clear error.
Self-represented prisoners or detained individuals who file motions for preliminary injunctions in federal court, particularly those whose cases proceed through magistrate judge review.
What happened
In Wren v. Bollin (No. 25-CV-3623), James D. Wren, a self-represented prisoner in Moose Lake, Minnesota, filed a lawsuit against a prison warden and two other officials. As part of that lawsuit, Wren asked the court for a preliminary injunction — a court order that would require the defendants to do something (or stop doing something) while the case is still ongoing.
United States Magistrate Judge Leo I. Brisbois issued a Report and Recommendation on April 27, 2026, recommending that the motion for a preliminary injunction be denied. Neither Wren nor the defendants objected to that recommendation within the allowed time period. When no one objects, the district court reviews the recommendation only for clear error — a limited form of review.
Judge Jeffrey M. Bryan found no clear error in the magistrate judge's recommendation and adopted it in full. As a result, Wren's motion for a preliminary injunction was denied. The court's order does not resolve the underlying lawsuit, only this specific motion.
The detailed version
- Wren v. Bollin · No. 0:25-cv-03623
- Jeffrey M. Bryan
- Aug. 3, 2026
Background
Petitioner James D. Wren, self-represented and located in Moose Lake, Minnesota, filed this action against William Bollin (Warden, named in his official capacity), Gary (Sargeant, named in his official and individual capacities), and Terra O'Conner (Lieutenant, named in her official and individual capacities). The respondents are represented by the Minnesota Attorney General's Office.
The opinion does not describe the underlying substantive claims of the lawsuit. The only matter addressed by this order is Wren's motion for a preliminary injunction (Doc. No. 16).
Magistrate Judge's Report and Recommendation
United States Magistrate Judge Leo I. Brisbois issued a Report and Recommendation (R&R) dated April 27, 2026, recommending denial of Wren's motion for a preliminary injunction. The opinion does not detail the specific reasons set forth in the R&R.
Standard of Review
Neither party filed objections to the R&R within the time allowed under District of Minnesota Local Rule 72.2(b)(1). When no timely objections are filed, the district court reviews the R&R only for clear error — meaning the court looks to see whether the magistrate judge made an obvious mistake, rather than reviewing the recommendation from scratch. The court 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 Bryan found no clear error in the R&R and adopted it in full. The motion for a preliminary injunction (Doc. No. 16) was denied. The order directs that judgment be entered accordingly.
Scope and Limitations
This order resolves only the preliminary injunction motion. The opinion does not address the merits of the underlying claims, indicate what those claims are, or reflect any final disposition of the case as a whole.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.