Catchings v. Dulgov

CourtDistrict Court, D. Arizona
DecidedAugust 28, 2025
Docket4:22-cv-00388
StatusUnknown

This text of Catchings v. Dulgov (Catchings v. Dulgov) is published on Counsel Stack Legal Research, covering District Court, D. Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Catchings v. Dulgov, (D. Ariz. 2025).

Opinion

1 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Deshon Catchings, No. CV 22-388-TUC-JAS

10 Petitioner, ORDER

11 v.

12 A. Dulgov,

13 Respondent. 14 15 DISCUSSION 16 Pending before the Court is a Report and Recommendation issued by United States 17 Magistrate Judge Ferraro. The Report and Recommendation recommends denying the 18 Petition. Petitioner filed objections to the Report and Recommendation.1 19 As a threshold matter, as to any new evidence, arguments, and issues that were not 20 timely and properly raised before United States Magistrate Ferraro, the Court exercises its 21 discretion to not consider those matters and considers them waived.2 See United States v.

22 1 Unless otherwise noted by the Court, internal quotes and citations have been omitted when citing authority throughout this Order. 23 2 As a general matter, the Court notes that it has had numerous problems with parties in many cases attempting to raise new issues that could have been raised before the United 24 States Magistrate Judge. The Court does not abide such actions, and allowing such actions undermines the Court’s ability to properly manage the hundreds of cases pending before 25 the Court. See United States v. Ramos, 65 F.4th 427, 435 n. 5 (9th Cir. 2023) (“Ramos's motion for reconsideration argued that the district court failed to conduct de novo review 26 because the order adopting the report and recommendation stated that ‘as to any new ... arguments ... not timely ... raised before [the magistrate judge], the Court exercises its 27 discretion to not consider those matters and considers them waived” even though, according to Ramos, the case raised no waiver issue. But this argument misses the point. 28 The fact that the order contained extraneous language does not negate the district court's multiple assertions that it conducted de novo review and the magistrate judge's proper 1 Howell, 231 F.3d 615, 621-623 (9th Cir. 2000) (“[A] district court has discretion, but is not 2 required, to consider evidence presented for the first time in a party's objection to a 3 magistrate judge's recommendation . . . [I]n making a decision on whether to consider 4 newly offered evidence, the district court must . . . exercise its discretion . . . [I]n providing 5 for a de novo determination rather than de novo hearing, Congress intended to permit 6 whatever reliance a district judge, in the exercise of sound judicial discretion, chose to 7 place on a magistrate judge's proposed findings and recommendations . . . The magistrate 8 judge system was designed to alleviate the workload of district courts . . . To require a 9 district court to consider evidence not previously presented to the magistrate judge would 10 effectively nullify the magistrate judge's consideration of the matter and would not help to 11 relieve the workload of the district court. Systemic efficiencies would be frustrated and the 12 magistrate judge's role reduced to that of a mere dress rehearser if a party were allowed to 13 feint and weave at the initial hearing, and save its knockout punch for the second round . . 14 . Equally important, requiring the district court to hear evidence not previously presented 15 to the magistrate judge might encourage sandbagging. [I]t would be fundamentally unfair 16 to permit a litigant to set its case in motion before the magistrate, wait to see which way 17 the wind was blowing, and—having received an unfavorable recommendation—shift gears 18 before the district judge.”); United States v. Reyna-Tapia, 328 F.3d 1114, 1122 (9th Cir. 19 2003) (“Finally, it merits re-emphasis that the underlying purpose of the Federal 20 Magistrates Act is to improve the effective administration of justice.”). 21 Assuming that there has been no waiver, the Court has conducted a de novo review 22 as to Petitioner’s objections. See 28 U.S.C. § 636(b)(1)(C) (“Within fourteen days after 23 being served with [the Report and Recommendation], any party may serve and file written 24 objections to such proposed findings and recommendations as provided by rules of court. 25 A judge of the court shall make a de novo determination of those portions of the report or 26 specified proposed findings or recommendations to which objection is made. A judge of 27 the court may accept, reject, or modify, in whole or in part, the findings or

28 analysis in recommending denial of the motion to suppress.”). 1 recommendations made by the magistrate judge. The judge may also receive further 2 evidence or recommit the matter to the magistrate judge with instructions.”). 3 In addition to reviewing the Report and Recommendation and any objections and 4 responsive briefing thereto, the Court’s de novo review includes review of the record and 5 authority before United States Magistrate Judge Ferraro (see Docs. 1 to 20). 6 Upon de novo review of the record and authority herein, the Court finds Petitioner’s 7 objections to be without merit, rejects those objections, and adopts United States 8 Magistrate Judge Ferraro’s Report and Recommendation. See, e.g., United States v. 9 Rodriguez, 888 F.2d 519, 522 (7th Cir. 1989) (“Rodriguez is entitled by statute to de novo 10 review of the subject. Under Raddatz [447 U.S. 667 (1980)] the court may provide this on 11 the record compiled by the magistrate. Rodriguez treats adoption of the magistrate's report 12 as a sign that he has not received his due. Yet we see no reason to infer abdication from 13 adoption. On occasion this court affirms a judgment on the basis of the district court's 14 opinion. Affirming by adoption does not imply that we have neglected our duties; it means, 15 rather, that after independent review we came to the same conclusions as the district judge 16 for the reasons that judge gave, rendering further explanation otiose. When the district 17 judge, after reviewing the record in the light of the objections to the report, reaches the 18 magistrate's conclusions for the magistrate's reasons, it makes sense to adopt the report, 19 sparing everyone another round of paper.”); Bratcher v. Bray-Doyle Independent School 20 Dist. No. 42 of Stephens County, Okl., 8 F.3d 722, 724 (10th Cir. 1993) (“De novo review 21 is statutorily and constitutionally required when written objections to a magistrate's report 22 are timely filed with the district court . . . The district court's duty in this regard is satisfied 23 only by considering the actual testimony [or other relevant evidence in the record], and not 24 by merely reviewing the magistrate's report and recommendations . . . On the other hand, 25 we presume the district court knew of these requirements, so the express references to de 26 novo review in its order must be taken to mean it properly considered the pertinent portions 27 of the record, absent some clear indication otherwise . . . Plaintiff contends . . . the district 28 court's [terse] order indicates the exercise of less than de novo review . . . [However,] 1 brevity does not warrant look[ing] behind a district court's express statement that it engaged 2 in a de novo review of the record.”); Murphy v. International Business Machines Corp., 23 3 F.3d 719, 722 (2nd Cir. 1994) (“We . . .

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Catchings v. Dulgov, Counsel Stack Legal Research, https://law.counselstack.com/opinion/catchings-v-dulgov-azd-2025.