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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 9 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.”

On Social Security review, he does not require a residual functional capacity finding to repeat a medical opinion verbatim when the stated restrictions substantively account for each limitation.

“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.”

Recommends remand when the administrative law judge's explanation is too incomplete for meaningful substantial-evidence review and the omitted analysis could affect the residual functional capacity.

“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.”

For prolonged post-removal immigration detention, recommends supervised release when the detainee shows removal is not reasonably foreseeable and the government does not rebut that showing with specific evidence.

“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

Sits as judge of record on 28 U.S.C. 636(c) consent 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.’”

A request to seal court records must identify a specific injury, a compelling interest that outweighs public access, and a narrowly tailored scope; a blanket request is insufficient.

“any future requests to seal must state a specific injury if portions are not sealed, identify a compelling interest outweighing the public’s interest in open records, and ensure the desired seal is tailored accordingly, sealing no more than necessary.”

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.”

Holt v. Commissioner of Social Security
5:25-cv-00813-DAR · 2026-03-13
Social security appeal (plaintiff) Denied

“The Magistrate Judge’s Report and Recommendation (R. 16) is hereby ADOPTED. The Commissioner’s decision is hereby AFFIRMED.”

Schandel v. Commissioner of Social Security
5:25-cv-00921-CAB · 2026-04-06
Social security appeal (plaintiff) Denied

“Magistrate Judge Clay’s Report and Recommendation is ADOPTED and the Commissioner’s decision is AFFIRMED.”

Ortiz v. Commissioner of Social Security
1:25-cv-00703-BYP · 2026-03-19
Social security appeal (plaintiff) Granted

“the Court adopts the R&R (ECF No. 11), reverses the Commissioner's decision denying disability insurance benefits, and remands the case for renewed administrative proceedings not inconsistent with the R&R.”

Rigueiro-Orruela v. Director of the Detroit ICE Field Office
4:25-cv-02340-CAB · 2026-03-18
Habeas petition (petitioner) Granted

“I recommend the District Court GRANT the petition.”

Stevens v. Forshey
3:26-cv-00268-SO · 2026-07-01
Motion for writ of certiorari (respondent) Denied

“the court hereby adopts the Report and Recommendation, (ECF No. 8), and, accordingly, denies the Motion for Writ of Certiorari. (ECF No. 7.)”

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.

Put Judge Clay's record to work

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

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