Michael Preston v. Warden Harold May

CourtDistrict Court, N.D. Ohio
DecidedFebruary 23, 2026
Docket1:22-cv-01976
StatusUnknown

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

Bluebook
Michael Preston v. Warden Harold May, (N.D. Ohio 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO EASTERN DIVISION

MICHAEL PRESTON, CASE NO. 1:22 CV 1976

Petitioner,

v. JUDGE JAMES R. KNEPP II

WARDEN HAROLD MAY,

Respondent. MEMORANDUM OPINION AND ORDER

Petitioner Michael Preston, a prisoner in state custody, filed a Petition seeking a writ of habeas corpus under 28 U.S.C. § 2254. (Doc. 1). This case was referred to Magistrate Judge Amanda M. Knapp for a Report and Recommendation (“R&R”) regarding the Petition under Local Civil Rule 72.2(b)(2). On November 12, 2025, Judge Knapp issued an R&R recommending the Court deny Petitioner’s grounds for relief and dismiss the Petition. (Doc. 11). Petitioner filed objections to the R&R. (Doc. 14). The Court has jurisdiction over the Petition under 28 U.S.C. § 2254(a). For the reasons set forth below, the Court overrules Petitioner’s objections, adopts the R&R, and denies and dismisses Petitioner’s habeas Petition. BACKGROUND This habeas case, filed on October 26, 2022, stems from Petitioner’s January 2020 convictions for reckless homicide, aggravated robbery, murder, and felonious assault. See Doc. 1; State v. Preston, 2021 WL 2765175 (Ohio Ct. App.). In his habeas Petition to this Court, Petitioner raised three grounds for relief: Ground No. 1: A Criminal Defendant Michael Preston State and Federal Constitutional rights are violated when his conviction stands on Insufficient Evidence.

Ground No. 2: When the trial court admits Gruesome Photographs of Body parts where there is no dispute over the cause of death, it violates State Evidence rules and the State and Federal Constitutions.

Ground No. 3: The Trial Court violates the Accused’s right to Due Process and a fair trial when it permits a prosecution witness to comment on the credibility of a pre-trial identification process.

(Doc. 1, at 7, 13, 16). In her R&R, Judge Knapp recommends the Court deny Ground One on the merits, dismiss and/or deny Grounds Two and Three as not cognizable and meritless. See Doc. 11, at 11-34. STANDARD OF REVIEW When a party objects to the Magistrate Judge’s R&R, the district judge “must determine de novo any part of the magistrate judge’s disposition that has been properly objected to. The district judge may accept, reject, or modify the recommended disposition; receive further evidence; or return the matter to the magistrate judge with instructions.” Fed. R. Civ. P. 72(b)(3). This Court adopts all uncontested findings and conclusions from the R&R and reviews de novo those portions of the R&R to which specific objections are made. 28 U.S.C. § 636(b)(1); Hill v. Duriron Co., 656 F.2d 1208, 1213-14 (6th Cir. 1981). To trigger de novo review, objections must be specific, not “vague, general, or conclusory.” Cole v. Yukins, 7 F. App’x 354, 356 (6th Cir. 2001). This specific-objection requirement is meant to direct this Court to “specific issues for review.” Howard v. Sec’y of Health & Human Servs., 932 F.2d 505, 509 (6th Cir. 1991). General objections, by contrast, ask this Court to review the entire matter de novo, “making the initial reference to the magistrate useless.” Id. 2 “A general objection, or one that merely restates the arguments previously presented and addressed by the Magistrate Judge, does not sufficiently identify alleged errors in the [R&R]” to trigger de novo review. Fondren v. Am. Home Shield Corp., 2018 WL 3414322, at *2 (W.D. Tenn.) (citing Howard, 932 F.2d at 509); see also Aldrich v. Bock, 327 F. Supp. 2d 743, 747 (E.D. Mich. 2004) (“An ‘objection’ that does nothing more than state a disagreement with a magistrate’s

suggested resolution, or simply summarizes what has been presented before, is not an ‘objection’ as that term is used in this context.”). General objections trigger only clear-error review. EEOC v. Dolgencorp, LLC, 277 F. Supp. 3d 932, 965 (E.D. Tenn. 2017), aff’d, 899 F.3d 428 (6th Cir. 2018). DISCUSSION Ground One As to Ground One, Petitioner’s sufficiency of the evidence claim, Petitioner presents a multi-pronged objection. See Doc. 14, at 4-7. First, he contends there was insufficient evidence to identify him as the perpetrator. Second, he argues that, because reckless homicide is a lesser included offense of murder, his conviction on reckless homicide demonstrates there is insufficient

evidence to convict him of murder. Third, and finally, Petitioner challenges the reliability of DNA evidence presented at trial. Petitioner, in essence, re-argues the purported merits of his claims and does not identify specific errors in the Magistrate Judge’s analysis. This is insufficient to trigger de novo review. See Phillips v. Turner, 2017 WL 2221591, at *3 (N.D. Ohio) (“[A]n Objection to an R & R is not meant to be simply a vehicle to rehash arguments set forth in the petition, and the Court is under no obligation to review de novo objections that are merely an attempt to have the district court reexamine the same arguments set forth in the petition and briefs.”); Aldrich, 327 F. Supp. 2d at 747. Nevertheless, on de novo review, the Court finds the R&R accurately sets forth clearly

3 established federal law regarding the sufficiency of the evidence, and correctly concludes that the Ohio appellate court’s determination of this issue was not contrary to or an unreasonable application of that law. See Doc. 11, at 11-22; 28 U.S.C. § 2254(d)(1). Petitioner’s objection regarding Ground One is overruled. Grounds Two & Three

As with Ground One, Petitioner’s objections to the Magistrate Judge’s recommended disposition of Grounds Two and Three simply re-argue his claims and do not present specific objections to the R&R. See Phillips, 2017 WL 2221591, at *3; Aldrich, 327 F. Supp. 2d at 747. Again, the Court finds the Magistrate Judge thoroughly reviewed and analyzed Petitioner’s claims that he was entitled to habeas relief based on the trial court’s admission of autopsy photographs and a detective’s testimony regarding the pretrial identification process. On de novo review, the Court agrees with and adopts the R&R’s well-reasoned analysis and conclusion that Grounds Two and Three present non-cognizable state law claims and that Petitioner has not demonstrated that these evidentiary determinations violated his due process rights. See Doc. 11, at

23-34. Double Jeopardy Finally, Petitioner asserts “a double jeopardy clause violation applies to his case and argument herein.” (Doc. 14, at 9) (capitalization altered). But Petitioner did not present this argument to the Magistrate Judge in his Petition or his Reply/Traverse. See Docs. 1, 9.1 Parties cannot “raise at the district court stage new arguments or issues that were not presented” before the Magistrate Judge’s final R&R. Murr v. United States, 200 F.3d 895, 902 n.1 (6th Cir. 2000)

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Related

Brown v. Ohio
432 U.S. 161 (Supreme Court, 1977)
Robert Dale Murr v. United States
200 F.3d 895 (Sixth Circuit, 2000)
Aldrich v. Bock
327 F. Supp. 2d 743 (E.D. Michigan, 2004)
David Swain v. Commissioner of Social Security
379 F. App'x 512 (Sixth Circuit, 2010)
Equal Emp't Opportunity Comm'n v. Dolgencorp, LLC
899 F.3d 428 (Sixth Circuit, 2018)
Cole v. Yukins
7 F. App'x 354 (Sixth Circuit, 2001)
Equal Employment Opportunity Commission v. Dolgencorp, LLC
277 F. Supp. 3d 932 (E.D. Tennessee, 2017)

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Michael Preston v. Warden Harold May, Counsel Stack Legal Research, https://law.counselstack.com/opinion/michael-preston-v-warden-harold-may-ohnd-2026.