HATTON v. WARDEN SUPERINTENDENT SHERIFF et al

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF FLORIDA
TALLAHASSEE DIVISION
VALERIE NASHAI HATTON,
Petitioner,
v. 	Case No. 4:26cv209-MW-HTC
WARDEN SUPERINTENDENT SHERIFF, et al,
Respondents.
______________________/
REPORT AND RECOMMENDATION
Valerie Nashai Hatton, a pretrial detainee proceeding pro se, has filed a
petition for writ of habeas corpus seeking relief under 28 U.SC. § 2241.1 Doc. 1.
As an initial matter, the petition, which is not on the Court’s approved forms, is
mostly nonsensical and indecipherable and contains language bearing the hallmark
of 	“sovereign 	citizen” 	or 	other 	“Redemptionist” 	theories, 	which 	have 	been
repeatedly rejected by the courts. 	For example, in the caption Hatton describes
herself as a “flesh-and-blood living woman” and the “living beneficiary” of a “Cestui
Que Trust,” both of which are common statements associated with those discredited
theories. 	See, e.g., Thomas v. All In Credit Union, 2023 WL 9197752, at *6 (S.D.
1 Along with the petition, Hatton also filed several nonsensical documents, including: Consolidated
Non-statutory Miscellaneous Filing (Doc. 4); Bill of Complaint in Equity and Petition for Relief
Upon Equitable and Trust Principles (Doc. 5); and Notice of Filing Certificate of Trust for Public
Record (Doc. 6). 	These documents are based on the same sovereign citizen theories discussed
herein and shall not be considered.
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Case No. 4:26cv209-MW-HTC
Ala. Dec. 7, 2023), report and recommendation adopted, 2024 WL 312682 (S.D.
Ala. Jan. 25, 2024). That said, from what the Court can discern, Hatton appears to
be challenging her pretrial detention in the Second Judicial Circuit for Leon County
Case No. 2012 CF 963.2 After reviewing the petition and other documents, the
undersigned concludes this case should be dismissed under Younger v. Harris, 401
U.S. 37 (1971), and as frivolous.
I. 	Background3
Hatton is a pretrial detainee currently housed at the Leon County Detention
Facility, in Tallahassee, Florida, after being charged in 2021 with felony murder in
the second degree, armed robbery, burglary of a dwelling, aggravated battery on a
law enforcement officer, false imprisonment, tampering with a witness, and petit
theft. 	See https://cvweb.leonclerk.com/public/online_services/search_courts/ (last
accessed 5/18/2026).4
It appears Hatton was released on bond and remained at liberty until she failed
to appear for a September 18, 2025, hearing, at which time a bench warrant was
issued. See docket entry 152 in state case, showing capias was issued for failing to
2 In addition to requesting nonsensical accounting and trust-related relief, Hatton requests that the
Court “ORDER Petitioner’s IMMEDIATE AND UNCONDITIONAL RELEASE from pretrial
detention on the grounds that her Sixth, Fifth, Eighth, Fourteenth and First Amendment rights have
been continuously violated for over five (5) years.”
3 The following information is taken from the petition, unless otherwise stated.
4 A federal court may properly take judicial notice of state court dockets. Paez v. Sec’y, Fla. Dep’t
of Corr., 947 F.3d 649, 652 (11th Cir.), cert. denied sub nom. Paez v. Inch, 141 S. Ct. 309 (2020);
see also Fed. R. Evid. 201(b)(2).
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appear. She was arrested on March 5, 2026. 	See docket entry 185-188. Her state
criminal case is pending, and a case management conference has been set for June
2, 2026.
II. 	Discussion
As discussed below, Hatton’s petition should be dismissed on two grounds.
First, the Court should abstain from exercising jurisdiction under Younger v. Harris.
Second, the petition is premised on frivolous sovereign citizen theories.
Under Younger v. Harris, 401 U.S. 37 (1971), a court may abstain from
hearing constitutional claims if: “(1) there are ongoing state proceedings, (2) the
proceedings implicate an important state interest, and (3) the state proceedings
provide an adequate opportunity for a party to raise constitutional challenges.
Tribble v. Tew, 653 F. App’x 666, 667 n.2 (11th Cir. 2016) (citation omitted).
Here, Younger abstention is required because each of those factors are met.
First, the petition arises from criminal proceedings pending in state court. Second,
criminal proceedings implicate important state interests. 	See Turner v. Broward
Sheriff’s Off., 542 F. App’x 764, 767 (11th Cir. 2013) (noting that “criminal
proceedings involve important state interests”); see also Hughes v. Att’y Gen. of Fla.,
377 F.3d 1258, 1262 (11th Cir. 2004) (“When a petitioner seeks federal habeas relief
prior to a pending state criminal trial the petitioner must satisfy the ‘Younger
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abstention hurdles’ before the federal courts can grant such relief.”) (citation
omitted).
Third, Hatton has an adequate opportunity to present her constitutional
arguments in the state criminal proceedings. Hatton can present her claims involving
the evidence against her in the circuit court or, in the event she is convicted, through
appellate and post-conviction proceedings. 	And she can challenge her pretrial
detention through a state “petition for a writ of habeas corpus and release from pre-
trial detention in the relevant Florida District Court of Appeals and, if the court
denie[s] the petition, … could [seek] review in the Supreme Court of Florida.”
Colley v. Fla., No. 3:25-CV-2040-LC/MJF, 2026 WL 730133, at *3 (N.D. Fla. Feb.
9, 2026), report and recommendation adopted, No. 3:25-CV-2040-LC/MJF, 2026
WL 715787 (N.D. Fla. Mar. 13, 2026) (citing Magbanua v. McNeil, 310 So. 3d 138,
141 (Fla. Dist. Ct. App. 2021)). 	Therefore, Hatton has adequate remedies to
challenge her pretrial detention in state court. See Daniels v. Geraldi, 578 F. App’x
811, 	811 	(11th 	Cir. 	2014) 	(explaining 	an 	“[a]dequate 	opportunity 	to 	raise
constitutional challenges exists so long as state procedural law does not bar the party
from raising the constitutional claim”); 31 Foster Child. v. Bush, 329 F.3d 1255,
1279 (11th Cir. 2003) (noting “plaintiffs have the burden of establishing that the state
proceedings do not provide an adequate remedy for their federal claims” and “[a]
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federal court ‘should assume that state procedures will afford an adequate remedy,
in the absence of unambiguous authority to the contrary’”) (citations omitted).
Although there are three narrow exceptions to the abstention doctrine, none
apply here. 	See Johnson v. Florida, 32 F.4th 1092, 1099 (11th Cir. 2022) (setting
forth the exceptions). 	First, there is no evidence that the state proceedings are
motivated by bad faith. Id. In the Younger context, bad faith “generally means that
a prosecution has been brought without a reasonable expectation of obtaining a valid
conviction.” 	Kugler v. Helfant, 421 U.S. 117, 126 n.6 (1975). 	Nothing about the
nature of the criminal proceedings shows that to be the case. Hatton’s allegation that
she has suffered “five years of pretrial detention” without any justification (Doc. 1
at 14) is belied by the record, which shows she was on pretrial release from April
2021 to March 2026. Also, the record shows that the defense requested or agreed to
each 	continuance 	and 	that 	defendant 	herself 	delayed 	the 	case 	with 	myriad
nonsensical pleadings. 	Moreover, her contention that the Court’s “total non-
response to all filings collectively constitute[s] a pattern of retaliation” (Doc. 1 at
17) is belied by the record. 	Likewise, her claim that the Court denied self-
representation is false, as she was given a hearing under Faretta v. California, 422
U.S. 806 (1975), and allowed to represent herself on March 31, 2026. 	See docket
entry 215.
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Second, Hatton has not shown that irreparable injury would occur. 	See
Kugler, 421 U.S. at 124 (noting “the cost, anxiety, and inconvenience of having to
defend against a single criminal prosecution alone do not constitute ‘irreparable
injury’ in the ‘special legal sense of that term’”). 	Lastly, for the reasons set forth
above, Hatton has not demonstrated there is no adequate alternative state forum
where the issues in the petition can be raised.
Based on the foregoing, this Court should abstain from reaching the merits of
Hatton’s § 2241 petition and dismiss it. 	See Johnson, 32 F.4th at 1099-1102
(affirming dismissal of § 2241 petition under Younger where Florida pretrial
detainee alleged his right to a speedy trial was being violated).
Finally, even absent Younger, Hatton’s petition is entirely frivolous because
it is premised on sovereign citizen theories, which have been repeatedly rejected by
the courts. 	See e.g., Greaves v. Mann, 2016 WL 11260337, at *1 (N.D. Ga. Nov.
17, 2016), report and recommendation adopted, 2017 WL 510894 (N.D. Ga. Feb. 8,
2017) (dismissing 28 U.S.C. § 2241 petition based on frivolous sovereign citizen
theories) (citing Linge v. State of Ga., Inc., 569 F. App’x 895, 896 (11th Cir. 2014)
(“[ [T]o the extent that] the plaintiff ... argues that he is a sovereign citizen and is not
subject to the jurisdiction of Georgia state courts or Georgia laws, both we and the
district court lack jurisdiction to consider his claim because it is ‘wholly insubstantial
and frivolous.’”) (citations omitted); United States v. Davis, 586 F. App’x 534, 536-
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37 (11th Cir. 2014) (“Previously, we've noted that so-called ‘sovereign citizens’ are
individuals who believe they are not subject to courts' jurisdiction[.] ... We've further
said that courts repeatedly have been confronted with sovereign parties or to state a
claim involving a substantial question of federal law.”).
Accordingly, it is RECOMMENDED:
1. 	That 	Hatton’s 	petition 	for 	writ 	of 	habeas 	corpus 	(Doc. 	1) 	be
DISMISSED.
2. 	That the filings at Doc. 4, Doc. 5, and Doc. 6 be stricken as procedurally
deficient and nonsensical.
3. 	That the clerk close the file.
At Pensacola, Florida, this 22 th day of May, 2026.
/s/ Hope Thai Cannon
HOPE THAI CANNON
UNITED STATES MAGISTRATE JUDGE
NOTICE TO THE PARTIES
Objections to these proposed findings and recommendations must be filed within
fourteen (14) days of the date of the Report and Recommendation. Any different
deadline that may appear on the electronic docket is for the court’s internal use only
and does not control. An objecting party must serve a copy of its objections upon
all other parties. A party who fails to object to the magistrate judge’s findings or
recommendations contained in a report and recommendation waives the right to
challenge on appeal the district court’s order based on the unobjected-to factual and
legal conclusions. See 11th Cir. Rule 3-1.
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