Darrell A. Clay

U.S. District Court for the Northern District of Ohio (Western Division, Toledo) 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; eight-year term, sworn in by Chief Judge Patricia A. Gaughan) 4 signed orders read

How Judge Clay decides

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

What persuades

On Social Security review he applies deferential substantial-evidence review but will recommend remand when the ALJ fails to build 'an accurate and logical bridge' between the recited evidence and the result -- articulation, not just outcome, matters. In Garcia he remanded a childhood-SSI denial because the ALJ did not explain how a teacher's 'serious'/'obvious' problems and conflicting state-agency reviews supported a 'less than marked' domain finding.

“a district court cannot uphold an ALJ's decision, even if there is enough evidence in the record to support the decision, [where] the reasons given by the trier of fact do not build an accurate and logical bridge between the evidence and the result.”

On Fourth Amendment habeas he forecloses relief at the threshold under Stone v. Powell: a 2254 claim premised on an allegedly illegal search is non-cognizable so long as the state gave a full and fair opportunity to litigate it, which Ohio's motion-to-suppress-and-appeal mechanism supplies.

“a Fourth Amendment claim which, under Stone v. Powell, 428 U.S. 465 (1976), is non-cognizable in federal habeas proceedings so long as the petitioner received a full and fair opportunity for judicial consideration of that claim in state court.”

Procedural preferences

Sits as judge of record on 28 U.S.C. 636(c) consent (docket suffix -DAC) and enters final judgment himself; a SS case referred to him for an R&R can convert to a consent final once the parties consent under Rule 73. His R&Rs also carry a standard objections notice warning that general objections that merely restate briefing are treated as waiver of appellate review.

“Objections must be specific and not merely indicate a general objection to the entirety of the Report and Recommendation; "a general objection has the same effect as would a failure to object."”

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.

Social security appeal
N = 3
counts only
Habeas petition
N = 1
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.

Elizabeth Swartz v. Commissioner of Social Security
3:24-cv-02196-DAC · 2025-09-18
Social security appeal (plaintiff) Denied

“The parties then consented to my exercising jurisdiction under 28 U.S.C. 636(c) and Fed. R. Civ. P. 73. (ECF #6). For the reasons below, I AFFIRM the Commissioner's decision.”

Shane M. Bobak v. Commissioner of Social Security
1:24-cv-02165 · 2026-02-03
Social security appeal (plaintiff) Denied

“the Report and Recommendation issued by Magistrate Judge Darrell A. Clay on September 18, 2025, denying Shane M. Bobak's application for Disability Insurance Benefits ... This Court ADOPTS the findings of fact and conclusions of law set forth by Magistrate Judge Clay over Mr. Bobak's objections.”

Erica Garcia, on behalf of T.G. (a minor) v. Commissioner of Social Security
3:24-cv-01240-JRK · 2025-04-24
Social security appeal (plaintiff) Granted

“I recommend the District Court REVERSE the Commissioner's decision denying supplemental security income and REMAND the matter for further proceedings. ... the lack of a logical bridge here from the recited evidence to the domain finding is not harmless.”

Spencer Brown v. Warden Michael Swartz (Fender)
4:22-cv-01284 · 2025-06-05
Habeas petition (petitioner) Denied

“the December 17, 2024, Report and Recommendation (R&R) ... by United States Magistrate Judge Darrell A. Clay recommending that the petition of Spencer Brown for a writ of habeas corpus under 28 U.S.C. 2254 be dismissed as non-cognizable. ... the Magistrate Judge's Report and Recommendation (R. 10) is hereby ADOPTED and Petitioner's single claim for habeas relief is DISMISSED as non-cognizable.”

Caseload & timing

From public federal docket records for this judge.

Qualitative, NOT a census. As a Toledo Western-Division magistrate judge he handles (a) referred civil R&R matters -- Social Security 405(g) appeals and 28 U.S.C. 2254 habeas dominate his written merits work (the reasoning layer above), across many Article III judges (Nugent, Ruiz, Knepp II, Barker seen as adopters/referrers); (b) 636(c) consent civil cases (mainly SS appeals) where he enters final judgment (suffix -DAC); and (c) directly-assigned duty-magistrate criminal matters -- notably a high volume of seizure/search warrants (incl. large domain-name forfeiture warrants) in 2026.