Darrell A. Clay
How Judge Clay rules, drawn from 29 signed orders. Every observation links to the order it came from.
About Judge Clay
Darrell A. Clay has served as a United States Magistrate Judge for the Northern District of Ohio since May 14, 2021. He earned a law degree from Tulane University School of Law in 1994. Before his appointment, he clerked for a Louisiana appellate judge and practiced law in Cleveland.
Judge Clay's practices and standing orders
Rules for cases before Judge Clay, as published on the court's website (checked October 9, 2026). Judges revise these often, so confirm the current version on the court's site before you file.
Key rules
Conferences
Named individuals, entity representatives, and lead counsel must attend the settlement conference.
“All named individual parties and the authorized representatives of all named corporate, governmental, or other parties must attend the settlement conference, together with lead counsel for each party.”
Conferences
A claimant seeking affirmative relief must send an itemized damages demand to opposing counsel 28 days before the settlement conference.
“no later than twenty-eight days prior to the settlement conference, each counsel for a party seeking affirmative relief (‘claimant’s counsel’) must submit a written itemization of damages and settlement demand to opposing counsel”
Conferences
Each party must submit a confidential settlement statement to the magistrate judge at least 14 days before the conference.
“Each party must submit a confidential settlement statement to me no later than fourteen days prior to the settlement conference.”
Standing orders for every case in this court
Orders the court applies to all of its cases, whichever judge has them, as published on the court's website (checked October 9, 2026).
How Judge Clay decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
In Garcia, Clay recommended remand because the administrative law judge did not explain how the evidence supported a less-than-marked childhood-benefits domain finding; the omission could affect disability eligibility.
“the lack of a logical bridge here from the recited evidence to the domain finding is not harmless.”
In Brown, Clay recommended dismissal under Stone v. Powell because Ohio provided an adequate opportunity to litigate the Fourth Amendment claim. The recommendation resolved cognizability rather than the suppression claim’s merits.
“Ohio’s procedural mechanism that frustrated presentation of his Fourth Amendment claim in the Ohio courts. Because Mr. Brown received a full and fair opportunity to litigate his Fourth Amendment claim, review of that claim through a habeas corpus petition is precluded under Stone v. Powell. See Good, 729 F.3d at 640; see also Loza v. Mitchell, 705 F.Supp.2d 773, 860 10 Case: 4:22-cv-01284-DAR Doc #: 10 Filed: 12/17/24 11 of 14. PageID #: <pageID> (S.D. Ohio Mar. 31, 2010) (holding that defendant received a full and fair opportunity to litigate his Fourth Amendment claim where the trial court heard and denied his motion to suppress and the defendant subsequently raised the same Fourth Amendment claim on direct appeal); Johnson v. Eppinger, No. 1:19 CV 984, 2020 WL 8771326, at *14 (N.D. Ohio June 1, 2020) (same), report and recommendation adopted, 2021 WL 861509 (N.D. Ohio Mar. 8, 2021); Long v. Watson, No. 3:22-cv- 503, 2022 WL 15522935, at *1 (N.D. Ohio Oct. 27, 2022) (same). In his Traverse, Mr. Brown seeks to circumvent the bar against federal collateral review under Stone by seizing on the Supreme Court’s statement that ‘a state prisoner may not be granted federal habeas corpus relief on the ground that evidence obtained in an unconstitutional search or seizure was introduced at his trial.’ (ECF #8 at PageID 379). He claims he is not challenging evidence introduced at trial because he entered a no contest plea and thus, his claim should be reviewed on the merits. (Id.). Mr. Brown does not identify case law supporting his position that a no-contest plea in the state trial court allows a petitioner to side-step the bar to a merits review of the Fourth Amendment claim. Case law within the Sixth Circuit indicates that Stone applies to the federal court’s review of Fourth Amendment claims even when the petitioner pled no contest. See Harding v. Russell, 156 F.App’x 740 (6th Cir. 2005); Scott v. Sheldon, No. 19-3164, 2019 WL 4187702 (6th Cir. 2019); Johnson v. Turner, No, 1:13CV01173, 2015 WL 3967673 (N.D. Ohio June 30, 2015); Coleman v. Richard, No. 15-cv-1962, 2018 WL 400322 (N.D. Ohio Jan. 11, 2018); Hays v. Bracy, No. 5:22-CV-01103-JPC, 2024 WL 643166 (N.D. Ohio Jan. 26, 2024), report and recommendation adopted, 2024 WL 639618 (N.D. Ohio Feb. 15, 2024). Next, Mr. Brown asserts that his claim—that the police officers did not have reasonable articulable suspicion that he was engaged in, or about to be engaged in, criminal activity—is 11 Case: 4:22-cv-01284-DAR Doc #: 10 Filed: 12/17/24 12 of 14. PageID #: <pageID> ‘quantitatively and qualitatively different’ from the issues in Stone, and therefore must be adjudicated on the merits. (ECF #8 at PageID 379). Not so. The Fourth Amendment’s prohibition on unreasonable seizures allows temporary detentions, known as Terry stops, if there is ‘a reasonable suspicion supported by articulable facts that criminal activity may be afoot.’ United States v. Sokolow, 490 U.S. 1, 7 (1989); see also Terry v. Ohio, 392 U.S. 1, 30 (1968). Stone acts to preclude litigation of all Fourth Amendment claims raised on federal habeas review, including the correctness of the state court’s decision on the reasonableness of an investigative stop, if the petitioner had a full and fair opportunity to litigate the claim in state court. Stone, 428 U.S. at 494- 95. Described above, Ohio’s procedural mechanism to adjudicate Fourth Amendment claims is adequate and there is no indication the state failed to provide Mr. Brown the mechanism to address his Fourth Amendment claim. Thus, his claim is not cognizable on federal habeas review.”
In Schandel, Clay concluded that the residual functional capacity sufficiently accounted for the examiner’s limitations without repeating the medical opinion verbatim.
“while the RFC does not include Mr. Bousquet’s opinions verbatim, the specific limitations it imposes reflect each of the four limitations to which he opined.”
In Ortiz, Clay recommended remand for an explanation of how the medical record conflicted with the doctor’s opinion, so the consistency finding could receive meaningful review.
“I thus recommend that on remand, the ALJ must explain how the medical record is inconsistent with Dr. Diab’s opinion such that meaningful review of the ALJ’s conclusions for substantial evidence can be conducted.”
In Rigueiro-Orruela, Clay recommended supervised release because the government did not rebut the detainee’s showing that removal was not reasonably foreseeable.
“I find Respondent has not rebutted Mr. Rigueiro-Orruela’s showing of good cause and recommend the District Court grant his petition and order the Respondent to release him on suitable terms of supervision consistent with 8 U.S.C. § 1231(a)(3).”
Procedural preferences
In Stevens, Clay recommended denying the request for sealed state-court transcripts because the State had not sought relief from the issuing court’s sealing order or shown circumstances warranting federal intervention.
“Nor has the State established extraordinary or other circumstances calling for federal intervention at this time.”
Signed rulings
A grounded sample of orders signed by this judge, with the verbatim dispositive language.
“Following review of the arguments presented, the record, and the applicable law, I recommend the District Court AFFIRM the Commissioner’s decision denying disability insurance benefits and supplemental security income.”
“Following review of the arguments presented, the record, and the applicable law, I recommend the District Court REVERSE the Commissioner’s decision denying disability insurance benefits and REMAND for further administrative proceedings not inconsistent with this Report and Recommendation.”
“Following review of the arguments presented, the record, and the applicable law, I recommend the District Court AFFIRM the Commissioner’s decision denying supplemental security income.”
“Following review of the arguments presented, the record, and the applicable law, and for the reasons described, I recommend the District Court REVERSE the Commissioner’s decision denying supplemental security income and REMAND for additional proceedings consistent with this recommendation.”
“After reviewing the record, the parties’ arguments, and the law, I REVERSE the Commissioner’s decision denying supplemental security income and REMAND for additional proceedings consistent with this Memorandum Opinion and Order.”
“Following review of the arguments presented, the record, and the applicable law, I recommend the District Court AFFIRM the Commissioner’s decision denying disability insurance benefits and supplemental security income.”
“After reviewing the record, the parties’ arguments, and the law, I AFFIRM the Commissioner’s decision denying supplemental security income.”
“After review of the record, the parties’ arguments, and the law, I AFFIRM the Commissioner’s decision denying disability insurance benefits and supplemental security income.”
“For the foregoing reasons, I hereby DENY Defendants’ Motion to Dismiss.”
“Following review of the arguments presented, the record, and the applicable law, I recommend the District Court REVERSE the Commissioner’s decision denying supplemental security income and REMAND the matter for further proceedings.”
“Following review of the arguments presented, the record, and the applicable law, I AFFIRM the Commissioner’s decision denying disability insurance benefits.”
“After review of the record, the parties’ arguments, and the law, I AFFIRM the Commissioner’s decision denying disability insurance benefits.”
Caseload & timing
From public federal docket records for this judge.
Clay's sampled civil work is concentrated in Social Security appeals and habeas matters. In referred cases he issues recommendations for the assigned district judge; in consent cases he enters final judgment himself. His directly assigned criminal-duty work also includes search- and seizure-warrant matters. This description is based on sampled matters rather than a complete census.
Pending matters in the official report
Reported by the Administrative Office of the U.S. Courts under the Civil Justice Reform Act, as of March 31, 2026.
| Motions pending more than six months | 0 |
| Bench trials submitted more than six months | 0 |
| Bankruptcy appeals pending more than six months | 0 |
| Social Security appeals pending more than six months | 0 |
| Civil cases pending more than three years | 0 |
| Report | Motions over six months | Cases over three years |
|---|---|---|
| Mar 2026 | 0 | 0 |
| Sep 2025 | 0 | 0 |
| Mar 2025 | 0 | 0 |
| Sep 2024 | 0 | 0 |
| Mar 2024 | 1 | 0 |
| Sep 2023 | 0 | 0 |
| Mar 2023 | 1 | 1 |
| Sep 2022 | 1 | 0 |
| Mar 2022 | 0 | 0 |
| Sep 2021 | 0 | 0 |
A snapshot on that date: matters listed may since have been decided or reassigned. A motion referred to a magistrate judge is counted for both judges. Motions in multidistrict litigation, section 2255 cases and Social Security appeals are not counted, and a very large three-year count is generally a multidistrict docket. Source: Appendix A of the report (PDF); about the report.
How long civil cases take in this court
For the whole of U.S. District Court for the Northern District of Ohio (Western Division, Toledo), not for Judge Clay: median time from filing to disposition of the civil cases the court closed in the 12 months ending September 30, 2025, as reported by the Administrative Office of the U.S. Courts.
| Cases | Median time | |
|---|---|---|
| All civil cases closed | 2,048 | 7.1 months |
| Closed with no court action | 394 | 3.3 months |
| Closed before pretrial | 1,035 | 5.9 months |
| Closed during or after pretrial | 607 | 11.4 months |
| Closed during trial | 12 | 18 months |
| 12 months ending | Cases closed | Median time |
|---|---|---|
| Sep 2025 | 2,048 | 7.1 months |
| Sep 2024 | 2,008 | 7.4 months |
| Sep 2023 | 2,137 | 8.5 months |
| Sep 2022 | 2,330 | 9.8 months |
| Sep 2021 | 2,432 | 9.3 months |
| Sep 2020 | 2,788 | 10.3 months |
| Sep 2019 | 3,158 | 9.9 months |
The table leaves out prisoner petitions, land condemnations, deportation reviews, recovery of overpayments and enforcement of judgments, and reports no median for fewer than 10 cases. A district that closed a large multidistrict litigation in the period shows very large counts and long medians for that year. Source: Table C-5, U.S. District Courts (spreadsheet).
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