Keita v. Huckell
Mamady Kalifa Keita v. Scott Huckell; Matthew Russell; Jonanthan C. Peterson; Randy Erdman; Jason Oetterer; and Kenneth Peterson, all in their individual capacities
- Jerry Blackwell
- 0:24-cv-00598
- U.S. District Court · District of Minnesota
- 2
In Keita v. Huckell, Judge Blackwell granted summary judgment for all defendants and dismissed the case after finding no clear error in the magistrate judge's report.
Individuals who have filed civil suits against government or other officials in their individual capacities, particularly those who receive an adverse magistrate judge report and do not file timely objections — a failure that limits district court review to the deferential 'clear error' standard.
What happened
In Keita v. Huckell et al. (Civ. No. 24-598), plaintiff Mamady Kalifa Keita sued six individual defendants — Scott Huckell, Matthew Russell, Jonanthan C. Peterson, Randy Erdman, Jason Oetterer, and Kenneth Peterson — in their individual capacities. The defendants moved for summary judgment, asking the court to rule in their favor without a full trial.
United States Magistrate Judge Elsa M. Bullard issued a Report and Recommendation on July 31, 2026, analyzing the motion. Keita did not file any objections to that recommendation within the time allowed. Under the applicable rules, when no objections are filed, the district court reviews the report only for clear error — a deferential standard — rather than conducting a fresh review.
Judge Jerry W. Blackwell found no clear error in the magistrate judge's report and accepted it in full. As a result, the defendants' motion for summary judgment was granted, a separate letter request filed by the plaintiff was denied as moot (meaning it was unnecessary to address given the outcome), and the case was dismissed.
The detailed version
- Keita v. Huckell · No. 0:24-cv-00598
- Jerry W. Blackwell
- Aug. 24, 2026
Background
Plaintiff Mamady Kalifa Keita brought suit against six defendants — Scott Huckell, Matthew Russell, Jonanthan C. Peterson, Randy Erdman, Jason Oetterer, and Kenneth Peterson — each sued in their individual capacities. The opinion does not describe the underlying facts or the specific legal claims at issue beyond identifying the defendants and their capacity.
Procedural History
Defendants filed a Motion for Summary Judgment (Doc. No. 67). Summary judgment is a pretrial ruling that ends a case in the moving party's favor when there is no genuine dispute of material fact and the moving party is entitled to judgment as a matter of law. The motion was referred to United States Magistrate Judge Elsa M. Bullard, who issued a Report and Recommendation (R&R) on July 31, 2026 (Doc. No. 95). An R&R is a magistrate judge's written analysis and proposed disposition, which a district judge then reviews.
Plaintiff Keita also filed a letter request (Doc. No. 89), the contents of which the opinion does not describe.
Standard of Review
Keita did not file any objections to the R&R within the permitted time. Under Federal Rule of Civil Procedure 72(b) and Eighth Circuit precedent (citing Grinder v. Gammon, 73 F.3d 793, 795 (8th Cir. 1996)), when no timely objections are filed, the district court reviews the R&R only for clear error — a highly deferential standard that requires obvious mistakes before the court can decline to follow the recommendation.
Rulings
Judge Blackwell found no clear error in the R&R and accepted it in full. The court's order:
- Accepted the July 31, 2026 R&R (Doc. No. 95).
- Granted Defendants' Motion for Summary Judgment (Doc. No. 67).
- Denied as moot Plaintiff's letter request (Doc. No. 89) — meaning that because the case was resolved against the plaintiff, the request no longer required a decision.
- Dismissed the case, with the court directing that judgment be entered accordingly.
Notes
The opinion itself is brief and does not set out the factual background, the nature of the claims, or the substantive analysis underlying the R&R. The merits analysis and the reasons for granting summary judgment are contained in the magistrate judge's R&R (Doc. No. 95), which is not reproduced here.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.