Teresa Ann Waters v. Ken Paxton, Attorney General of Texas, et al.

Petitioner seeks prospective, declaratory and injunctive relief from state actors who are applying and enforcing state and federal statutes in a manner that violates the due process, substantive due process and equal protection of the 14th Amendment to the U.S. Constitution and the Dictionary Act 1 U.S.C. § 1. In 2002, Petitioner Ms. Waters’ conviction required lifetime registration as a Texas sex offender; how­ ever, after implementation of the Adams Walsh Child Protection Act of 2007, Ms. Waters was eligible for deregistration. In an attempt to continue collecting federal funding, Respondents registered Ms. Waters as a Tier III sex offender under 18 U.S.C. § 2241(c) which requires a conviction of crossing state lines with a victim under 12 years of age. Ms. Waters never had any state or federal conviction of crossing state lines and her victim was over 12 years of age.

1. Whether Ms. Waters is a Tier III sex offender according to 18 U.S.C. § 2241(c).

2. Whether Ms. Waters is a Tier I sex offender according to Adam Walsh Act (2007).

3. Whether Respondents are violating the U.S. Constitution, 14th Amendment by restraining Ms. Waters’ civil liberties under the provisions of 18 U.S.C. § 2241(c) where no such convictions exist and no such crimes were committed by Petitioner.