MARTINEZ
v.
CHRONISTER (HILLSBOROUGH)
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Martinez filed a federal habeas corpus petition under 28 U.S.C. § 2241 challenging her detention in Hillsborough County jail on an out-of-state fugitive warrant. The district court dismissed the petition without prejudice because Martinez failed to exhaust available state court remedies before seeking federal relief, and she was simultaneously pursuing relief in state court.
A federal court cannot grant a § 2241 petition unless the petitioner has exhausted all available state remedies. Martinez's petition was dismissed without prejudice because she failed to exhaust state court remedies and was simultaneously proceeding in both state and federal court for the same relief.
[1] A federal court may grant relief under 28 U.S.C. …
[2] The exhaustion of state remedies doctrine applies to petitions for a writ of habeas corpus filed under 28 U.S.C. …
Previewing 2 of 5 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“The exhaustion doctrine is a judicially crafted instrument which reflects a careful balance between important interests of federalism and the need to preserve the writ of habeas corpus as a swift and imperative remedy in all cases of illegal restraint or confinement.”
Establishes the foundational rationale for the exhaustion requirement in habeas corpus cases, from Braden v. 30th Judicial Circuit of Kentucky.
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Join FLexlaw to unlock all legal intelligenceMartinez was detained in Hillsborough County jail pursuant to an out-of-state fugitive warrant. Counsel was appointed to represent her, and a petition…
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Martinez applies under 28 U.S.C. § 2241 for the writ of habeas corpus and challenges her detention in the Hillsborough County jail under an out-of-state fugitive warrant. Relief under Section 2241 is the proper remedy because Martinez asserts no challenge to a state court judgment. Although jurisdiction resides in the federal courts, Martinez cannot proceed in federal court before presenting the claim to the state courts — a process called exhaustion of state court remedies — as explained in Braden v. 30th Judicial Circuit of Kentucky, 410 U.S. 484, 490 (1973) (internal quotation omitted):
The exhaustion doctrine is a judicially crafted instrument which reflects a careful balance between important interests of federalism and the need to preserve the writ of habeas corpus as a swift and imperative remedy in all cases of illegal restraint or confinement.
Unlike Section 2254, which explicitly requires exhaustion, Section 2241 contains no statutory exhaustion requirement. Nevertheless, a party seeking relief under Section
2241 must present the claim to the state court before seeking relief in federal court. Moore v. DeYoung, 515 F. 2d 437, 442 (3rd Cir. 1975), explains that “although there is a distinction in the statutory language of §§ 2254 and 2241, there is no distinction insofar as the exhaustion requirement is concerned." Accord Johnson v. Florida, 32 F. 4th 1092, 1095–96 (11th Cir. 2022) (“It is by now well-settled that district court may not grant a Section 2241 petition 'unless the petitioner has exhausted all available state remedies.") (quoting Georgalis v. Dixon, 776 F. 2d 261, 262 (11th Cir. 1985)); Thomas v. Crosby, 371 F. 3d 782, 812 (11th Cir. 2004) (“Among the most fundamental common law requirements of § 2241 is that petitioners must first exhaust their state court remedies.") (Tjoflat, J., concurring) (citing Braden and Moore).
Martinez fails to show that she has exhausted the available state court remedies before seeking relief in federal court. Moreover, a review of the online docket for the circuit court for Hillsborough County shows both that counsel was appointed to represent Martinez and that a petition for the writ of habeas corpus was recently filed in state court. Martinez cannot simultaneously proceed with an action in both a state court and a federal district court to obtain the same relief.
The application for the writ of habeas corpus (Doc. 1) is DISMISSED WITHOUT PREJUDICE. The clerk must close this case.
ORDERED in Tampa, Florida, on August 11, 2025.
STEVEN D. MERRYDAY
UNITED STATES DISTRICT JUDGE
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Braden v. 30TH Jud. Cir. Court OF Ky., 410 U.S. 484 (U.S. 1973)
- Johnson v. State, 32 F.4th 1092 (11th Cir. 2022)
- Thomas v. Crosby, 371 F.3d 782 (11th Cir. 2004)
- Moore v. DeYOUNG, 515 F.2d 437 (3d Cir. 1975)
- Georgalis v. Dist. Attorney Donnie Dixon, 776 F.2d 261 (11th Cir. 1985)