SUPERIOR COURT OF RIDGEWAY
TOPFLOORGEEK69,
Petitioner,
v.
TACTICALDANKPATRIOT, Sergeant in the
Ridgeway State Police, in his official capacity,
Respondent.
Civil Action No. RSC-CV-5195
RESPONDENT’S BRIEF IN OPPOSITION
Respondent, proceeding by and through the Solicitor General of Ridgeway, hereby files a
brief in opposition to the Petition for Writ of Habeas Corpus pursuant to 1 R. Stat. § 2211 and
respectfully requests that the Court deny the Petition.
Dated: August 5, 2025 Respectfully submitted,
Palmer, Ridgeway.
/s/ BrendaPopplewell
BrendaPopplewell
Solicitor General
EffortlessBrit
Deputy Solicitor General
Ridgeway Department of Justice
1 County Annex
Palmer, Ridgeway 33368
Attorneys for Defendant
SUPERIOR COURT OF RIDGEWAY
TOPFLOORGEEK69,
Petitioner,
v.
TACTICALDANKPATRIOT, Sergeant in the
Ridgeway State Police, in his official capacity,
Respondent.
Civil Action No. RSC-CV-5195
RESPONDENT’S BRIEF IN OPPOSITION
AND AFFIDAVIT OF PROBABLE CAUSE
FACTUAL BACKGROUND
On July 22, 2025, Twitchlly was standing next to a Ridgeway Credit Union van parked in
Sterling Heights, Ridgeway, while carrying in his hands a rifle. Two employees of the Ridgeway
Credit Union were inside the van; and Petitioner TopFloorGeek69 was secretly watching the van
and Twichlly from a nearby Ridgeway Credit Union building. Twitchlly did not exhibit any signs
of aggression. Although he carried a rifle, Twitchlly did not point it toward the Ridgeway Credit
Union van or indicate that he was going to do them any harm. Indeed, Twitchlly was not looking
in the direction of the Ridgeway Credit Union van nor exhibiting any sign of aggression.
At some point, one of the employees in the van said: “yeah I think he[‘s] try[ing] [to] kill
us[.]” Twitchlly verbally denied this suggestion, and turned his body even further away from the
van. During this time, Petitioner was secretly watching the encounter—including the employees’
baseless suggestion that Twitchlly was attempting to ‘kill’ them and Twitchlly peacefully turning
his body away from the van. Accordingly, Petitioner reasonably should have known that Twitchlly
did not pose a threat of harm. Nonetheless, a few moments later, Geek exited the Ridgeway Credit
Union Building and opened fire on Twitchlly. Twitchlly died on the scene.
The killing was reported to Sergeant TacticalDankPatriot of the Ridgeway State Police and
Petitioner was later arrested for voluntary manslaughter in violation of Rid. Crim C. § 3.07 which
makes a felony punishable by jail the act of “caus[ing] the death of another in the heat of passion.”
Id. On June 29, 2025, Petitioner filed this Petition for Writ of Habeas Corpus seeking an order
expunging the arrest record. Petitioner does not contest that Sergeant Patriot acted with probable
cause; still, he requests habeas relief because he is “[actually] innocent.” Pet. ¶ 13-16.
LEGAL STANDARD
In reviewing a petition for habeas corpus, a court of competent jurisdiction “shall either
grant or deny review of the petition based on its merits.” 1 R. Stat. § 2211. Accordingly, “[t]he
Court may * * * deny or grant a petition.” Id. If habeas corpus is issued, courts will next determine
“whether the police were lawfully entitled to make [the] arrest.” In re Zachcasisbeast, 1 R. Supp.,
at 12 (2022). That is, if the police officer “had probable cause that a crime was committed.” Id.
If the arrest was unlawful, “the inquiry ends there; the record must be removed.” Id. But if the
arrest was lawful, the next question is whether the applicant is “actually innocent of the charge or
charges for which they were arrested.” Id. Here, the arrest here is lawful, and Petitioner’s conduct
falls squarely within the type of killing expressly prohibited under Rid. Crim. C. § 3.06.
ARGUMENT
I. Petitioner Geek Did Not Act in Defense of Others
Sergeant Patriot arrested Geek for voluntary manslaughter under Rid. Crim C. § 3.07
which makes a felony the act of “caus[ing] the death of another in the heat of passion.” Id.1 But
this case is an odd one: Geek admits that he killed Twitchlly and does not deny that Sergeant Patriot
had probable cause to lawfully arrest him. Nonetheless, Petitioner asserts that he is “[actually]
innocent.” Pet. ¶ 13-16. To support that claim, Petitioner argues that his actions were lawful under
a proposed “Defense of Others” defense to liability. Id. Although such an affirmative defense does
not exist in Ridgeway law, the State concedes—as it must—that a person who truly engages in
lawful self-defense or in defense of others is not guilty of felony under Rid. Crim. C. § 3.07.
At first, that interpretation may seem odd. After all, Section 3.07 does not contain any
explicit limitations in its language and broadly applies to “whoever * * *” violates its terms. Id.
But Congress does not intend absurd outcomes. United States v. Kirby, 7 Wall. 482, 486-87 (1868).
(“All laws should receive a sensible construction. [Words] should be so limited in their application
1 “Whoever causes the death of another in the heat of passion.” Id.
as not to lead to * * * an absurd consequence.”) Thus, we assume “[Congress] intends exceptions
to its language which would avoid [absurd] results,” id. at 487. See also FCC v. NextWave Personal
Communications Inc., 537 U. S. 293, 311 (2003) (BREYER, J., dissenting) (“‘Tell all customers that
. . .’ does not refer to every customer of every business in the world”).
So, too, here. The word “whoever,” as used in § 3.07, does not mean a person who engages
in lawful self-defense or comes to the rescue of another. See Utility Air Regulatory Group v. EPA,
573 U.S. 302, 310 (2014) (BREYER, J., concurring in part) (“The word ‘any,’ when used in a statute,
does not normally mean ‘any in the universe.’”) Compare Lon L. Fuller, The Case of the
Speluncean Explorers, 62 Harv. L. Rev. 616, 625 (1949).2 It is pursuant to a such legal rationale
that Geek comes before this Court. Particularly, Geek asserts that he shot Twitchlly in defense of
the Ridgeway Credit Union employees. But Twitchlly did not pose a threat of harm—let alone a
threat of serious physical injury or death necessary to justify Geek’s use of lethal force.
At all times, Twitchlly was facing in a different direction than the van and did not point his
rifle toward the Ridgeway Credit Union employees. When one of the employees falsely claimed
Twitchlly was “kill[ing]” them, Twitchlly replied “no” and turned himself even further away from
the employees. A video taken by Twitchlly shows that Geek was watching Twitchlly during the
entire encounter. Thus, Geek knew that the Ridgeway Credit Union employee who falsely claimed
that Twitchlly was “kill[ing]” them was, in fact, not telling the truth. Therefore, Geek’s conduct
falls squarely within the type of killing prohibited under Rid. Crim. C. § 3.07. And Geek cannot
hide under a “Defense of Others” affirmative defense to nullify the lawful arrest in this case.
2 (“The stupidest housemaid knows that when she is told “to peel the soup and skim the potatoes”
her mistress does not mean what she says. She also knows that when her master tells her to “drop
everything and come running” he has overlooked the possibility that she is at the moment in the
act of rescuing the baby from the rain barrel.”) (quotation marks in original).
CONCLUSION
For the foregoing reasons, Court should deny the Petition.
Dated: August 5, 2025 Respectfully submitted,
Palmer, Ridgeway.
/s/ BrendaPopplewell
BrendaPopplewell
Solicitor General
EffortlessBrit
Deputy Solicitor General
Ridgeway Department of Justice
1 County Annex
Palmer, Ridgeway 33368
Attorneys for Defendant
AFFIDAVIT
THE STATE OF RIDGEWAY
COUNTY OF RIDGEWAY
I, TacticalDankPatriot, state and depose as follows and declare the same to be true to the
best of my belief under pains and penalties of perjury–
1. I was patrolling the game and was at Sterling Gun Club when a resident, Twitchlly,
came up to me and asked if he could report a crime to me. He asked for a discord @ to send it to
and I told him my username where he then sent this clip.
2. In this clip, he was unlawfully displaying his firearm and posed no threat to RCU,
as he told them 'no' in reference to the 2 RCU in the bank truck believing that he was going to kill
them. It then shows topfloorgeek69 killing him with an MP5. After recieving and reviewing this
clip, I searched the map for topfloorgeek69 where I then detained him at the Walmart and brought
him to PPD station to arrest him.
3. From my understanding, this falls under voluntary manslaughter as he had no ill
intent but, was, as is stated on the spreadsheet, under 'heat of passion' which was fear in this
moment.
/s/ TacticalDankPatriot
TacticalDankPatriot
EXHIBIT A
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1wooHoo
v. Kozjan
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V---125
---24
District Court in Clark County
Video Evidence filed by Kozjani In Support of
Request for OSG Legal Representation
