Carmen E. Henderson
How Judge Henderson rules, drawn from 12 signed orders. Every observation links to the order it came from.
How Judge Henderson decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
She has recommended or ordered Social Security remand where an ALJ erred rather than reflexively affirming. The published reasoning sample contains four affirmances and two sentence-four remands, including Ledsome's unopposed remand and affirmances in Laliberte and Hatchett.
“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
Several referring district judges have adopted her recommendations when no party filed a timely objection after satisfying themselves that the record contained no clear error. To preserve a challenge, a party must file specific, timely objections; otherwise de novo review may be forfeited.
“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.
“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”
“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.”
“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.”
“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).”
“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.”
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.
“it is RECOMMENDED that the Court OVERRULE Hodges's Statement of Errors and AFFIRM the Commissioner's decision.”
“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)”
“Respondent's motion to dismiss for lack of personal jurisdiction be GRANTED, and that Purley's petition be DISMISSED WITHOUT PREJUDICE.”
“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.”
“the Court AFFIRMS the Commissioner of the Social Security Administration's final decision denying Tinsley benefits.”
“Therefore, the Court ADOPTS Magistrate Judge Henderson’s R&R (Doc. 13) as the Order of this Court and DENIES and DISMISSES WITHOUT PREJUDICE Petitioner’s Petition (Doc. 1) as set forth therein.”
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.
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