John M. Bodenhausen

United States District Court for the Eastern District of Missouri

How Judge Bodenhausen decides

Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.

What persuades

On warrantless forensic searches of electronic devices seized at the border, he applies the border-search exception and holds that Riley v. California (which requires a warrant for searches incident to arrest) does NOT carry over to the border context — the two exceptions address different needs. A Riley-based attack on a border device search is unlikely to persuade him.

“recommending that the Court deny the motion to suppress because the searches were performed within the border search exception to the warrant requirement.”

On a motion to dismiss an indictment, he applies the Eighth Circuit sufficiency standard (Steffan): an indictment is legally sufficient if it contains the essential elements of the charged offense, fairly informs the defendant, and lets him plead the judgment as a bar. Arguing the indictment must also plead a related civil statute (e.g., the CARES Act behind an 18 U.S.C. 1014 false-statement charge), or that the underlying scheme is void for vagueness, will not get a charge dismissed.

“An indictment is legally sufficient on its face if it contains all of the essential elements of the offense charged, fairly informs the defendant of the charges against which he must defend, and alleges sufficient information to allow a defendant to plead a conviction or acquittal as a bar to a subsequent prosecution.”

Procedural preferences

His Reports & Recommendations are adopted in full by the E.D. Mo. district judges with high regularity (observed: Ross, Autrey, Fleissig, and Pitlyk each adopting/sustaining his R&Rs). Summary, conclusory objections that restate the original motion without offering a countervailing rationale are routinely overruled — preserve issues with specific, reasoned objections, and make your full evidentiary record at his hearing.

“Defendant Gaten filed objections to the Report and Recommendation ... summarily stating that he objects to the conclusions drawn by Magistrate Judge Bodenhausen, but fails to provide any countervailing rationale for his position.”

On a prolonged-traffic-stop / interdiction theory, he closely examines whether the officer's actions exceeded the scope of the stop and, on developed records with experienced interdiction officers, has concluded the actions stayed within the stop's lawful scope. A bare 'the stop was prolonged' argument without a factual hook in the record is a weak posture before him.

“correctly concluded that the actions by Officer Smith did not improperly exceed the scope of the traffic stop.”

Cautions

He is not a rubber stamp for the government on statements: in at least two cases (Stewart, Hardge) he recommended GRANTING suppression of statements in part while denying suppression of physical evidence. A well-grounded Miranda/voluntariness/Seibert challenge to specific statements can succeed before him even when the physical-evidence search is upheld — target the statements precisely rather than seeking blanket suppression.

“the Motion to Suppress Statements [26] is GRANTED in part and DENIED in part, and the Motion to Suppress Physical Evidence is DENIED.”

Motion outcomes

Counted from classified signed orders only. Percentages are shown only where the sample is large enough to be meaningful; smaller samples are reported as raw counts.

Motion to suppress
N = 8
Granted in part: 2Denied: 6 counts only
Motions to dismiss
N = 3
Denied: 3 counts only

A "1 of 1" is one ruling, not a tendency. Treat small samples as illustrative, not predictive.

Signed rulings

A grounded sample of orders signed by this judge, with the verbatim dispositive language.

United States v. Orlando Stewart
4:15-cr-00556-JAR · 2016-08-02
Motion to suppress (defendant) Granted in part

“the Motion to Suppress Statements [26] is GRANTED in part and DENIED in part, and the Motion to Suppress Physical Evidence is DENIED.”

Motion to suppress (defendant) Denied

“the Motion to Suppress Statements [26] is GRANTED in part and DENIED in part, and the Motion to Suppress Physical Evidence is DENIED.”

United States v. Haitao Xiang
4:19-cr-00980-HEA · 2021-10-15
Motion to suppress (defendant) Denied

“Defendant's motion to suppress is DENIED.”

United States v. Eric Gaten
S1-4:22-cr-00642-JAR · 2025-03-28
Motion to suppress (defendant) Denied

“the Motion to Suppress Statements and Evidence [135] is DENIED.”

Motions to dismiss (defendant) Denied

“the Amended Motion to Dismiss Indictment/Counts [138] is DENIED.”

United States v. Eric Gaten
4:22-cr-00642-JAR · 2024-02-22
Motions to dismiss (defendant) Denied

“the Motions to Dismiss Indictments/Counts [87 and 89] are DENIED.”

United States v. Demean Hardge
4:23-cr-00031-SEP · 2024-08-19
Motion to suppress (defendant) Granted in part

“issued his Report and Recommendation on May 16, 2024, recommending that the undersigned grant the motion in part and deny it in part.”

United States v. John Kjar
4:24-cr-00331-HEA · 2024-12-12
Motions to dismiss (defendant) Denied

“In his October 15, 2024 Report and Recommendation, Judge Bodenhausen recommended Defendant's Motion be denied.”

United States v. Armani Tatum
S2-4:22-cr-00229-JAR · 2024-03-20
Motion to suppress (defendant) Denied

“the Motions to Suppress Evidence and Statements [680] is DENIED.”

United States v. Akai Aikens
4:22-cr-00387-HEA · 2024-04-09
Motion to suppress (defendant) Denied

“Defendant's Motion to Suppress Evidence, [Doc. No. 42] is denied.”

United States v. Shauwn Nettles
4:18-cr-01007-AGF · 2021-07-23
Motion to suppress (defendant) Denied

“Defendant's Motion to Suppress Evidence [Doc. No. 57] is DENIED.”

Caseload & timing

From public federal docket records for this judge.

Median case duration in the sampled dockets: 543 days (N = 6).

Median motion-to-ruling time: 94 days (N = 4).

Not systematically enumerated. The 9 Bodenhausen-assigned dockets surfaced span consent civil (insurance, other-statutory, civil-rights), Social-Security appeals, and a prisoner civil-rights matter, consistent with a magistrate judge's consent-and-SS docket. Nature-of-suit observed: Social Security DIWC/DIWW (Niemann, Daniel), 110 Insurance (Halpern), 890 Other Statutory (Roeslein), Civil Rights Other (Bulfin), Prisoner Civil Rights (Smalley v. Davis).