Richard Schomaker v. Kathryn Joblonski, et al.

CourtDistrict Court, W.D. Michigan
DecidedFebruary 25, 2026
Docket1:24-cv-00966
StatusUnknown

This text of Richard Schomaker v. Kathryn Joblonski, et al. (Richard Schomaker v. Kathryn Joblonski, et al.) is published on Counsel Stack Legal Research, covering District Court, W.D. Michigan primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Richard Schomaker v. Kathryn Joblonski, et al., (W.D. Mich. 2026).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

RICHARD SCHOMAKER,

Plaintiff, Case No. 1:24-cv-966 v. Hon. Hala Y. Jarbou KATHRYN JOBLONSKI, et al.,

Defendants. ___________________________________/ ORDER REGARDING REPORT AND RECOMMENDATION Plaintiff Richard Schomaker brings this civil rights action against multiple defendants, including Ingham County Animal Control (“ICAC”) and ICAC Officer Kathryn Joblonski. Before the Court is the report and recommendation of the magistrate judge that the Court grant the motion for summary judgment filed by Joblonski and ICAC. (R&R, ECF No. 101.) Schomaker has objected to the R&R. (Objs., ECF No. 102.) Under Federal Rule of Civil Procedure 72, 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). Schomaker’s claims stem from ICAC’s investigation of complaints that Schomaker was keeping cats without properly caring for them.1 Among other things, Schomaker claims that Joblonski violated his Fourth Amendment rights when she entered the curtilage of his home on

1 Michigan law makes it a crime for an “owner, possessor, . . . or person having charge or custody of an animal” to “fail to provide [the] animal with adequate care.” Mich. Comp. Laws § 750.50(2)(a). several occasions without a warrant, and again when she entered the curtilage of his home and peered inside his house and garage with a warrant in hand.2 The magistrate judge reviewed the evidence and determined that Schomaker failed to demonstrate the existence of a material factual dispute as to any of his Fourth Amendment claims. In other words, the warrantless entries were permissible under exceptions to the warrant requirement and the entry with the warrant was legal

because the warrant was valid. Schomaker objects to these conclusions. Objections re Search Warrant Objection 1: Lack of Nexus Schomaker argues that the search warrant was deficient insofar as it permitted ICAC to search his home because the warrant affidavit lacked a substantial basis for concluding that evidence of criminal activity (i.e., animal neglect) would be discovered inside his home or garage. The Court disagrees. The magistrate noted the following facts from the affidavit: the presence of numerous cats roaming on the Property, some of which were sick and required veterinary care and one of which had to be medically euthanized; Schomaker’s admission that he was aware of the impounded kitten’s need for veterinary care and failed to obtain such care; Schomaker’s statements that he would put lysine in the cats’ food to help with their upper respiratory infections and would seek veterinary care for the cats; the presence of one or more cat beds on the Property and Schomaker’s apparent placement of collars on some of the cats; and Schomaker’s admission that he had been feeding the cats for years. (R&R 24.) The magistrate judge also noted Joblonski’s observation in the affidavit regarding “conditions on the Property indicating that Schomaker showed signs of hoarding disorder, including hoarding of animals, and . . . that based on her training and experience, animal hoarders tend to harbor animals both inside and outside their residences.” (Id.)

2 Apparently, officials were not able to enter Plaintiff’s home or garage due to hoarded belongings inside these buildings that were blocking the entrances and that allowed the exterior doorways to open only partway. (See R&R 7; ICAC Rep., ECF No. 85-11, PageID.1317.) Schomaker objects that all the cats observed were outside the home and that training and experience cannot substitute for an evidentiary nexus between the offense and the place to be searched. Even so, there was a sufficient nexus in this case. It is common sense that an individual feeding and caring for multiple cats around their home is likely to be keeping some of those cats inside their home. Joblonski’s training and experience added additional support to what was

already a reasonable inference from the facts. See United States v. Branch, 537 F.3d 582, 589 (6th Cir. 2008) (permitting reliance on training and experience to support probable case). In addition, the warrant permitted the officer to search for veterinary records, which is the sort of evidence that was likely to be found inside Schomaker’s premises. Schomaker argues that this particular request was pretextual because officers had already obtained veterinary records associated with Schomaker’s address under the customer name “Ferlie Yruma.” (See R&R 4.) But that argument erroneously assumes the officers knew that those records were the only ones available. To the contrary, the officers could reasonably assume that other records might be available in Schomaker’s home, particularly where, as here, Schomaker had apparently attempted

to conceal his identity at the two clinics he visited. It is possible that copies of other records were present inside Schomaker’s home, and that those records were not readily available from veterinary clinics because they were not associated with Schomaker’s name or address. Schomaker compares this case to United States v. McPhearson, 469 F.3d 518 (6th Cir. 2006), in which the Sixth Circuit held that the arrest of an individual outside his home with drugs on his person was insufficient to establish that evidence of drug dealing would likely be found inside his home. Id. at 525. In particular, the court noted the absence of any evidence of drug trafficking, such as independent corroboration that the individual was a known drug dealer. Id. at 524-25. McPhearson is distinguishable because evidence of animal neglect was present at and around Schomaker’s home. In those circumstances, it was reasonable to infer that additional evidence of such neglect might be found inside his home as well. Schomaker also notes that when the officers executed the warrant, they found no cats inside the residence. That fact is immaterial because probable cause is determined based on facts known at the time the warrant issued, not at the time after its execution is complete. The absence of cats

inside the home or garage when the officers executed the warrant does not detract from the validity of the warrant or the search pursuant to that warrant. Relatedly, Schomaker objects to the magistrate judge’s assertion that an East Lansing ordinance permitting the feeding of stray cats was irrelevant to the probable cause finding. (See R&R 26.) That ordinance provides that “[n]o person shall have at any time outdoors on their property or property leased by them, or in any other place readily accessible by stray cats, more than one-half pound of cat food or food intended for consumption by cats.” (ECF No. 17-4, PageID.202.) Schomaker argues that this ordinance fatally undermines the theory of probable cause in his case, i.e., that feeding cats outdoors creates custody over the cats, because the

ordinance purportedly permits the outdoor feeding of stray cats over whom the homeowner does not have custody. This argument is not persuasive. The East Lansing ordinance says nothing about whether feeding stray cats creates custody under Michigan law. It simply limits the amount of cat food a resident can keep outdoors.

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Bluebook (online)
Richard Schomaker v. Kathryn Joblonski, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/richard-schomaker-v-kathryn-joblonski-et-al-miwd-2026.