Carmen E. Henderson

U.S. District Court for the Northern District of Ohio (Eastern Division) Appointed by U.S. District Judges for the Northern District of Ohio (merit-selected magistrate judge; magistrates are appointed by the district's Article III judges, not the President) 10 signed orders read

How Judge Henderson decides

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

What persuades

Recommends Social Security remand when the ALJ erred, not a reflexive affirm. In Ledsome she recommended reverse + sentence-four remand (the Commissioner did not object); in Laliberte and Hatchett she recommended affirming where work existed in the national economy / the denial was supported. 2 affirm vs 1 remand across the SS sample.

“On December 8, 2021, the magistrate judge submitted a Report (ECF No. 14) recommending that the Court reverse the Commissioner's decision and remand the case to the Commissioner.”

Habeas R&Rs resolve procedural default first and apply AEDPA's doubly-deferential standard; her analysis survived de novo review over a petitioner's objections. In Stein she found four grounds procedurally defaulted (claims not fairly presented through every level of Ohio's appellate process, no actual-innocence gateway because a meritorious suppression motion shows only legal insufficiency, not factual innocence) and three meritless under the 'doubly deferential' Strickland/AEDPA lens.

“the magistrate judge has now deemed to be procedurally defaulted ... Even a meritorious motion to suppress would establish only mere legal insufficiency, not factual innocence.”

Procedural preferences

Where no party objects, the referring district judges (Barker, Boyko, Gwin, Pearson) adopt her R&Rs after satisfying themselves there is no clear error on the face of the record; 4 of 5 merits R&Rs in this sample drew no objection. Practical takeaway: to preserve a challenge to her recommendation a party must file specific, timely objections -- general restatements of prior briefing are treated as waiver.

“When no timely objection is filed, the court need only satisfy itself that there is no clear error on the face of the record in order to accept the recommendation.”

Signed rulings

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

Raymond A. Miller v. Michael L. Phillips, Warden
1:20-cv-02135 · 2023-07-24
Habeas petition (petitioner) Denied

“the Report and Recommendation of Magistrate Judge Carmen E. Henderson. (Doc. No. 22), which recommends denial of the Petition for Writ of Habeas Corpus pending before the Court. No objections have been filed. ... the Court hereby denies the Petition for Writ of Habeas Corpus for the reasons stated by the Magistrate Judge in the Report and Recommendation”

Steven Mark Laliberte v. Commissioner of Social Security
5:22-cv-01856 · 2024-01-25
Social security appeal (plaintiff) Denied

“On September 21, 2023, the Magistrate Judge recommended affirming the Commissioner's decision which determined that Plaintiff is not disabled since work is available in the economy that Plaintiff can perform. ... Magistrate Judge Henderson's Report and Recommendation is ADOPTED and the Commissioner's decision is AFFIRMED.”

Crystal Hatchett, on behalf of minor L.F. v. Commissioner of Social Security
1:20-cv-00237 · 2021-02-17
Social security appeal (plaintiff) Denied

“On January 19, 2021, Magistrate Judge Henderson issued a Report and Recommendation (‘R&R’) recommending that this Court affirm the Commissioner's final decision. ... the Court ADOPTS Magistrate Judge Henderson's R&R, incorporates it as if fully restated herein, and AFFIRMS the Commissioner's final decision.”

David Ledsome v. Kilolo Kijakazi, Acting Commissioner of Social Security
5:20-cv-02495 · 2021-12-23
Social security appeal (plaintiff) Granted

“On December 8, 2021, the magistrate judge submitted a Report (ECF No. 14) recommending that the Court reverse the Commissioner's decision and remand the case to the Commissioner. ... the Report and Recommendation of the magistrate judge is hereby adopted. The decision of the Commissioner of Social Security is reversed and the case is remanded to the Commissioner for further proceedings and a new decision under sentence four of 42 U.S.C. 405(g).”

Scott Stein v. Warden Ed Sheldon
3:20-cv-02722 · 2024-02-21
Habeas petition (petitioner) Denied

“the report and recommendation (Doc. No. 15 (R&R)) of Magistrate Judge Carmen E. Henderson, recommending that this Court dismiss the petition for a writ of habeas corpus filed by pro se petitioner Scott Stein ... in its entirety. Stein filed objections to the R&R. ... Stein's objections to the R&R are OVERRULED, the R&R is ACCEPTED, Stein's petition is DISMISSED, and Stein's request for an evidentiary hearing is DENIED.”

United States v. Raymond C. Lattimer
5:23-cr-00274 · 2023-11-03

On consent referral, Henderson conducted a Rule 11 guilty-plea colloquy on October 20, 2023 and issued an R&R recommending acceptance of the defendant's plea to two child-pornography counts. On de novo review, District Judge Benita Y. Pearson found that Henderson 'in her careful and thorough proceeding... satisfied the requirements of Fed. R. Crim. P. 11 and the United States Constitution' and adopted the recommendation. Grounding quote: 'Upon de novo review of the record, the Report and Recommendation is adopted.' This was a plea recommendation rather than a contested motion outcome.

Cari Leeann Hodges v. Commissioner of Social Security
1:25-cv-02239 · 2026-07-06
Social security appeal (plaintiff) Denied

“it is RECOMMENDED that the Court OVERRULE Hodges's Statement of Errors and AFFIRM the Commissioner's decision.”

Shannon D. Loy v. Commissioner of Social Security
5:24-cv-02239 · 2025-09-10
Social security appeal (plaintiff) Granted

“it is RECOMMENDED that the Court REVERSE the Commissioner of Social Security's nondisability finding and REMAND this case to the Commissioner and the ALJ under Sentence Four of § 405(g)”

Roosevelt Purley v. Toledo Federal Court
3:24-cv-01211 · 2025-01-17
Habeas petition (petitioner) Denied

“Respondent's motion to dismiss for lack of personal jurisdiction be GRANTED, and that Purley's petition be DISMISSED WITHOUT PREJUDICE.”

Adefel Jose Viera Zue v. U.S. Attorney General
4:26-cv-00345 · 2026-03-31
Habeas petition (petitioner) Denied

“I recommend that the Court dismiss the petition without prejudice and deny Petitioner's pending motions for immediate release and expedited consideration, ECF Nos. 2, 3, as moot.”

Charles Tinsley v. Commissioner of Social Security Administration
1:25-cv-00427 · 2025-11-19
Social security appeal (plaintiff) Denied

“the Court AFFIRMS the Commissioner of the Social Security Administration's final decision denying Tinsley benefits.”

Caseload & timing

From public federal docket records for this judge.

The sampled work includes referred Social Security and habeas matters, criminal pretrial motions, plea proceedings, and criminal-duty complaints assigned directly to Judge Henderson. Several district judges reviewed or adopted her recommendations. This is a qualitative description of the sampled matters, not a complete caseload census.

Put Judge Henderson's record to work

Ezel drafts and answers grounded in this exact profile: how Judge Henderson actually rules, not a generic AI guess.

Opens in Ezel Pro. Every answer is grounded in Judge Henderson's own signed orders and cites them.