Hunt v. Lott

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 0:26-CV-60352-AUGUSTIN-BIRCH
SAMUEL J. HUNT,
Plaintiff,
v.
JONATHAN LOTT,
Defendant.
________________________________________/
REPORT AND RECOMMENDATION TO
DISMISS COMPLAINT WITHOUT PREJUDICE
This matter comes before the Court upon review of Plaintiff Samuel J. Hunt’s Complaint
and Emergency Motion for Temporary Restraining Order. 	DE 1; DE 3. 	Plaintiff names as the
sole Defendant Circuit Judge Jonathan Lott of the Seventeenth Judicial Circuit in and for Broward
County, 	Florida. 	Plaintiff 	challenges 	rulings 	and 	procedures 	in 	his 	active, 	state
dissolution-of-marriage case. 	See Hunt v. Hunt, No. FMCE16014948 (Broward Cnty., Fla.).1
While Plaintiff’s marriage was dissolved in 2018, the state case remains active with respect to
disputes over child timesharing. 	Plaintiff contends that rulings and procedures in the state case
violate his constitutional rights.
In particular, Plaintiff challenges the adjudication of a petition for a writ of habeas corpus
that he filed in the state case. The state docket reflects that he filed the petition in July 2025 and
that the state court denied the petition shortly thereafter. The state docket further reflects that the
Fourth District Court of Appeals determined in August 2025 that the petition was properly denied.
1 The Court takes judicial notice of the state docket. See Paez v. Sec’y, Fla. Dep’t of Corr., 947 F.3d 649, 652 (11th
Cir. 2020) (concluding that a district court properly could judicially notice online state court dockets).
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The Fourth District Court of Appeals stated that habeas relief is not available under Florida law to
collaterally litigate child custody where a different remedy is adequate and available.
Having 	reviewed 	Petitioner’s 	Complaint 	and 	Emergency 	Motion 	for 	Temporary
Restraining Order, the Court recommends abstention under Younger v. Harris and dismissal of the
Complaint without prejudice. See generally Younger v. Harris, 401 U.S. 37 (1971). A court may
dismiss a case sua sponte under Younger. See Boyd v. Georgia, 512 F. App’x 915 (11th Cir. 2013)
(affirming a sua sponte dismissal of a complaint under Younger); Hudson v. Hubbard,
358 F. App’x 116 (11th Cir. 2009) (same). “Younger requires a federal court to abstain where a
plaintiff’s federal claims could be adjudicated in a pending state judicial proceeding.” Leonard v.
Ala. State Bd. of Pharmacy, 61 F.4th 902, 907 (11th Cir. 2023) (quotation marks omitted).
Younger applies if there is an ongoing state judicial proceeding, the state proceeding implicates
important state interests, and there is an adequate opportunity in the state proceeding to raise
constitutional challenges. New Ga. Project, Inc. v. Att’y Gen., State of Ga., 106 F.4th 1237, 1242
(11th Cir. 2024).
Younger applies to require abstention in this case. First, Plaintiff’s state case is ongoing,
and the Complaint is an explicit challenge to the rulings and procedures in that case. See DE 1.
Second, the nature of the state case is domestic relations. States have an important interest
in their own domestic relations matters. Morancy v. Salomon, No. 24-12505, 2025 WL 1341957,
at *3 (11th Cir. May 8, 2025) (“The second [Younger] factor, requiring that the state proceeding
implicate important state interests, is satisfied because domestic relations issues have been
historically considered a state interest.”); Davis v. Self, 547 F. App’x 927, 930 (11th Cir. 2013)
(“There is no doubt that matters involving domestic relations and child custody implicate important
state interests.”); see also Ingram v. Hayes, 866 F.2d 368, 369 (11th Cir. 1988) (“The federal
judiciary has traditionally abstained from deciding cases concerning domestic relations.”).
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Third, a “federal court should assume that state procedures will afford an adequate remedy,
in the absence of unambiguous authority to the contrary.” 31 Foster Child. v. Bush, 329 F.3d 1255,
1279 (11th Cir. 2003) (quotation marks omitted). The third Younger factor “is not concerned with
questions of substance or equity, but is procedural.” Morancy, 2025 WL 1341957, at *3. Plaintiff
has the ability to raise his constitutional arguments through the state case. As all three Younger
factors are satisfied, the Court recommends abstention and dismissal of the Complaint without
prejudice. See Hale v. Pate, 694 F. App’x 682, 684 (11th Cir. 2017) (“Dismissals pursuant to the
Younger abstention doctrine are without prejudice.”). The Clerk of Court is directed to mail a
copy of this Report and Recommendation to Plaintiff at the address listed below and to make
a notation of such on the docket.
Within fourteen days after being served with a copy of this Report and Recommendation,
any party may serve and file written objections to any of the above findings and recommendations.
28 U.S.C. § 636(b)(1); S.D. Fla. Mag. R. 4(b). 	The parties are hereby notified that a failure to
timely object waives the right to challenge on appeal the District Court’s order based on
unobjected-to factual and legal conclusions contained in this Report and Recommendation.
11th Cir. R. 3-1.
DONE AND SUBMITTED in Chambers at Fort Lauderdale, Florida, this 17th day of
February, 2026.
___________________________________
PANAYOTTA AUGUSTIN-BIRCH
UNITED STATES MAGISTRATE JUDGE
Copy mailed to:
Samuel J. Hunt
10031 Camille Drive SE
Huntsville, AL 35803
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