IN THE SUPERIOR COURT OF THE
STATE OF RIDGEWAY
TAKOSII0,
Petitioner,
v,
AXCURXD, in his official capacity as a peace
officer with the Ridgeway County Sheriff’s
Office,
Respondent.
RESPONDENT’S BRIEF IN OPPOSITION
TO PETITION FOR HABEAS CORPUS
Docket Number: RSC-CV-8627
The Respondent, axcurxd, by and through the undersigned counsel, respectfully asks this
Court to dismiss the Petition for Habeas Corpus because it fails the Zachisbeast test. Among
other things, Petitioner’s claims are legally insufficient, given they cite old statutes and make
assertions that are legally impossible.
In support of these grounds, a brief in opposition is attached hereto.
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RESPONDENT’S BRIEF IN OPPOSITION
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FACTUAL BACKGROUND
1. On August 17, 2026, Petitioner was arrested by Respondent for violations of
Unauthorized Use of Emergency Lighting by a Security Company, contrary to R.C.C. §
5.13; Reckless Driving contrary to R.V.C. § 3.01; and Unauthorized Use of a Siren by a
Security Company, contrary to R.C.C. § 5.14. In the booking, Respondent provided the
following statement of probable cause to support the arrest: “Within Alder Limits;
Suspect was seen driving an RCU Percival with lights and sirens; RNG interchange
ALDER”.
2. A few hours later, Petitioner filed an Amended Petition for Habeas Corpus, challenging,
inter alia, that R.C.C. § 5.13 and R.C.C. § 5.14 are not actual offenses in the Ridgeway
Criminal Code, and therefore his federal constitutional rights under the Fifth and
Fourteenth Amendments have been violated. P. Hab. ¶ 14.
3. Those allegations are contradicted by State law.
4. Nearly a month before Petitioner's arrest, the Governor signed S12:11 into law, a bill
titled: “Necessary Amendments to the Security Company Emergency Lighting Act of
2026.”
5. Under this bill, Section 4(a) created new offenses, which included the two offenses which
Petitioner is charged with. The same offenses which Petitioner claims were “neither
enacted nor codified into law.” P. Hab. ¶ 14.
6. More specifically, Section 3 of the bill reads: “This act comes into effect upon the
signature of the Governor…”. Governor Rathuzen signed this bill on July 24, 2026, well
before the arrest of Petitioner.
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RESPONDENT’S BRIEF IN OPPOSITION
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ARGUMENT
I. THE PETITION FAILS THE ZACHCASISBEAST TEST AND MUST BE
DISMISSED
7. Every Petition for Habeas Corpus in the State of Ridgeway is subjected to the
Zachcasisbeast test. See IamOnCane v. RokuTitanite, RSC-CV-8569.
8. In In re ZachCasisbeast, the Court established a two-part test to determine whether or not
a petition for habeas corpus should be granted. The Court held that “the first question to
be asked is whether the police were legally entitled to make that arrest”. The second
question is “whether the petitioner was actually innocent of the charge or charges for
which they were arrested.”
9. The Court discussed that a petitioner can demonstrate actual innocence by “establishing
facts that make the prospect of a hypothetical conviction on the charges virtually
impossible.”
10. Here, the first question is whether the Respondent made a lawful arrest. Firstly, the
Respondent had the power to arrest the Petitioner for a violation of the Criminal Code
without warrant, as that power is derived under 6 R. Stat. § 131.006. The Respondent has
the power to make a warrantless arrest when that person has committed an offence in
their presence. The evidence shows that the Respondent observed Petitioner driving the
RCU vehicle while its lights activated in his presence. The evidence also shows Petitioner
recklessly driving by driving with disregard for the safety of persons and property in their
vicinity, namely by speeding, running a stop sign, and swerving into the wrong way of
traffic. Thus, the arrest was lawful.
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RESPONDENT’S BRIEF IN OPPOSITION
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11. The second question here is whether the Petitioner is actually innocent of these offenses.
Zachcasisbeast discussed that the standard to be used in this test is if a “reasonable and
well-informed jury could not convict the petitioner in a hypothetical trial if they were
aware of those facts, and those facts were admissible evidence.”
12. Therefore, we ought to conduct a hypothetical trial to test whether or not Petitioner is
innocent of these charges. Firstly, the evidence, which was captured by the Petitioner
himself, shows him driving an RCU Percival at 100spd speeds, failing to stop at a stop
sign, and weaving across lanes, all while his emergency lights are activated. These facts
would demonstrate to a well-informed jury that Petitioner drove in a manner which
disregarded the safety of persons and property in his vicinity.
13. As for the two charges of using emergency lights and siren while unauthorized, the
evidence shows that Petitioner was driving while the lights were activated in code 3
pattern. Given that Petitioner was driving in third-person view, a reasonable jury would
believe that Petitioner had to have known they were activated. This fact would also be
supported given Petitioner turns off his lights when he sees the Respondent approaching.
14. In conclusion, the arrest was lawful because Petitioner committed a crime in the presence
of Respondent, thus giving him the power to arrest him. The Petitioner could not be
innocent of these charges because the evidence is overwhelming, and a well-informed
jury would reasonably convict him.
II. PETITIONER'S DUE PROCESS AND FAIR-WARNING ARGUMENT FAILS
BECAUSE THE OFFENSES WERE ENACTED ALMOST A MONTH BEFORE
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RESPONDENT’S BRIEF IN OPPOSITION
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15. Petitioner argues even if these offenses were passed by the Senate (which they were), his
arrest is still unlawful because they were never codified. P. Hab. ¶ 15. This argument
completely fails because the offenses were in-fact codified into State law. See here.\
16. Petitioner’s Exhibit B is an outdated spreadsheet. The Senate, and Community Oversight
have made multiple announcements regarding new laws, code of statutes, etc. Just
because Petitioner has an outdated spreadsheet does not make his arrest illegal, or violate
his rights.
17. Petitioner's argument that he didn’t receive a fair warning of these offenses fail as well.
Although a citizen does not need to read the entire criminal code, a mistake of law is not
a valid reason for a habeas corpus writ. Here, Petitioner’s claim of a mistake of law could
only survive if the code of statutes did not contain these charges. See 6 R. Stat. §
122.301(b).
18. The Government has done its due diligence and informed the State of newly signed laws,
by updating the Code of Statutes, adding it to the official Senate Trello and Database, and
publicly announcing them in community Discord servers.
19. Petitioner cannot expect the Government to personally DM him every time a new law is
implemented.
20. Accordingly, Petitioner’s argument that the crime does not exist, and that he was never
notified fail, because the crimes do exist, and the Government made every reasonable
announcement/update to inform.
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RESPONDENT’S BRIEF IN OPPOSITION
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CONCLUSION
21. The Petition fails under the Zachcasisbeast, his own evidence, and his arguments.
22. In the Zachcasisbeast test, the Petition fails because (1) the arrest was lawful; and (2) a
well-informed and reasonable jury would not find Petitioner innocent of these charges.
23. The Petitioner's evidence shows exactly why he was arrested, and incriminates himself. It
does not support his case at all, and probably ruins it.
24. Lastly, Exhibit B clearly proves this Petition is a mistake, because Petitioner relies on
outdated law. The Government and Community Oversight has made updated law
available to everyone, even if they aren’t in a Discord server. The law is available through
the official website, Court website, Trello’s, and multiple Discord servers. Somehow,
Petitioner didn’t get the memo, and thinks that makes his arrest illegal. It does not.
25. Accordingly, the Petition should be denied.
Date: August 20, 2026
Respectfully submitted,
Detachment_Result
[Detachment_Result] State Bar No.
11103
Counsel for the Respondent
Deputy Attorney General
Ridgeway Department of Justice
Annex Building, Palmer City
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RESPONDENT’S BRIEF IN OPPOSITION
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