Michael L. Larr v. Warden Misty Mackey

CourtDistrict Court, S.D. Ohio
DecidedFebruary 27, 2026
Docket2:24-cv-01730
StatusUnknown

This text of Michael L. Larr v. Warden Misty Mackey (Michael L. Larr v. Warden Misty Mackey) is published on Counsel Stack Legal Research, covering District Court, S.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Michael L. Larr v. Warden Misty Mackey, (S.D. Ohio 2026).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION

Michael L. Larr, Petitioner, Case No. 2:24-cv-1730 Vv. Judge Michael H. Watson Warden Misty Mackey, Magistrate Judge Merz Respondent. OPINION AND ORDER Michael Larr (“Petitioner”), proceeding pro se in this habeas case, objects, ECF No. 42, to the Magistrate Judge’s Report and Recommendations (“R&R”) recommending dismissal of the Petition with prejudice, ECF No. 39. The objections were filed on December 19, 2025, and served on Warden Misty Mackey (‘Respondent’) the day before, but Respondent did not respond. They are thus ripe for decision. l. STANDARD OF REVIEW As required by 28 U.S.C. § 636(b)(1} and Federal Rule of Civil Procedure 72(b), the Court has reviewed de novo those portions of the R&R to which Petitioner properly objected. ll. ANALYSIS A. Jurisdiction At the beginning of the R&R, the Magistrate Judge noted the pendency of an appeal to the Sixth Circuit. R&R 1, ECF No. 39. The R&R recommended finding

that the appeal did not deprive this Court of jurisdiction because it was from an order of Magistrate Judge Deavers, but Petitioner failed to appeal it to the Undersigned before filing his Notice of Appeal. /d. (citing ECF Nos. 22 and 26). Petitioner objects, arguing first that he did not appeal from Magistrate Judge Deavers’ Order, ECF No. 22, but rather appealed from the District Court's Order denying reconsideration of Magistrate Judge Deavers’s Order, ECF No. 29. Obj. 1, ECF No. 42. He next contends that the District Court lacks jurisdiction to consider the merits of his habeas petition until the mandate issues from the Sixth Circuit on his appeal. As a preliminary matter, Petitioner's Notice of Appeal specifically cites the appealed order as having been “filed 02/12/25,” which was Magistrate Judge Deaver’s Order. See Not. of Appeal 1, ECF No. 26; Order, ECF No. 22. Moreover, the Notice of Appeal attached a copy of the order Petitioner appealed—Magistrate Judge Deavers’s Order. Not. of Appeal, ECF No. 26 at PAGEID ## 850-52. Regardless, the Sixth Circuit construed Petitioner's appeal as one of the Undersigned’s Order, see ECF No. 43, and the Court does not lack jurisdiction over the merits of Petitioner’s Petition, notwithstanding the lack of a mandate. Filing a notice of appeal deprives the District Court of jurisdiction only over those portions of the case involved in the appealed order and not the entire case. Marrese v. Am. Academy of Osteopathic Surgeons, 470 U.S. 373, 379 (1985) (citation omitted). Petitioner appealed only from the denial of his bond request. ECF No. 26. Thus, the Notice of Appeal does not transfer jurisdiction of the entire case to the Sixth Circuit, and this Court continues to have jurisdiction over the general issue of Case No. 2:24-cv-1730 Page 2 of 15

whether Petitioner is entitled to habeas corpus relief. B. Merits The Rules Governing § 2254 Proceedings require petitioners to construct their petitions on a standard form that provides for a statement of a ground for relief, followed by a statement of facts in support. See Habeas Rules 2(c) and (d) and attached standard form. Petitioner did not use the standard form or state separate grounds for relief. Instead, his Petition is constructed around seven “Assignments of Error.” Pet. ii-iii, ECF No. 1. Because Petitioner is proceeding pro se, the Magistrate Judge recognized the Petition was to be liberally construed. R&R 4, ECF No. 39. And because Petitioner's constitutional claims were spread across several grounds for relief (assignments of error), the R&R “attempt[s] to sort the claims by issue raised, rather than grouping the analysis under the Grounds for Relief as pleaded in the Petition.” /d. 1. AEDPA Deference Petitioner objects that, because the Ohio Supreme Court declined jurisdiction of his case, nothing the state trial or appeals courts had to say is relevant, and this Court is “only concerned with the Habeas Corpus, Response to State, this Response and the trial records.” Obj. 2, 5, ECF No. 42. In other words, he argues that this Court should have reviewed his claims de novo instead of applying the Antiterrorism and Effective Death Penalty Act of 1996 (Pub. L. No 104-132, 110 Stat. 1214) (‘AEDPA’) deference to those claims that the Ohio Fifth District Court of Appeals (“Fifth District”) decided on their merits. Case No. 2:24-cv-1730 Page 3 of 15

On the contrary, this habeas corpus Court reviews the last state-court decision on the merits of any constitutional issue. 28 U.S.C. § 2254(d)(1). Because the Ohio Supreme Court did not exercise its jurisdiction, it passed up its opportunity to pass on the merits. But that does not mean we can disregard the lower Ohio court decisions. 2. Judicial Notice Petitioner recites items of which the Magistrate Judge refused to take judicial notice, Obj. 3—4, ECF No. 42, but he fails to argue any error. As the Sixth Circuit explained, Petitioner is not entitled to have a judge take judicial notice of such “facts.” Order 3-4, ECF No. 43. 3. Assignment of Errors 1 and 3 At this point, Petitioner begins individually discussing his “Assignments of Error.” Obj. 5, ECF No. 42. As the Magistrate Judge did in the R&R, the Undersigned will also group together those assignments of error that overlap. In “Assignment of Error 1,” Petitioner claims to be actually innocent because he was arrested without probable cause. /d. (“100% innocent do [sic] to the arrest with a lack of probable cause. Which of course would violate the Fourth Amendment to be free.”). He accuses the Magistrate Judge of failing to consider this argument. /d. As for the merits, Petitioner contends that he was arrested based on nothing more than the “standalone hearsay of a child,” which, he argues, is insufficient to provide probable cause to support his arrest. /d. at 5-6 (citing United States v. Shaw, 464 F.3d 615 (6th Cir. 2006), and Wesley v. Campbell, 779 F.3d 421 (6th Cir. 2015)). Moreover, Petitioner maintains that his prior reliance on civil Case No. 2:24-cv-1730 Page 4 of 15

caselaw was appropriate. /d. at 7. Because his arrest violated his Fourth Amendment rights, he argues, he is innocent and need not submit any “new” evidence of his innocence to overcome a procedural default. /d. at 5, 7 ("A miscarriage of justice equals actual innocence and needs no new evidence.”). “Assignment of Error 3” likewise argues that Petitioner's “Fourth Amendment right to be free was violated when he was arrested with a lack of probable cause.” Obj. 8-9, ECF No. 42. “Assignment of Error 3” repeats the argument that his reliance on civil caselaw was reasonable and that the arrest without probable cause renders him “actually innocent” (again, apparently for purposes of overcoming any procedural default of this or other claims). /d. at 8-9 (“This means the error was prejudicial and a miscarriage of justice that gets viewed de-novo.”). As framed, Petitioner's argument misses the point of habeas corpus proceedings. Once a person has been indicted, the question of whether there was probable cause to charge that person in the first place becomes irrelevant, unless the State obtained evidence while the person was detained without probable cause. That is not the case here.

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Michael L. Larr v. Warden Misty Mackey, Counsel Stack Legal Research, https://law.counselstack.com/opinion/michael-l-larr-v-warden-misty-mackey-ohsd-2026.