IN THE SUPERIOR COURT OF THE
STATE OF RIDGEWAY
TAKOSII0,
Petitioner,
v,
DANNYDOESAPPROVE, in his official
capacity as a peace officer with the Ridgeway
State Police,
Respondent.
RESPONDENT’S BRIEF IN OPPOSITION
TO PETITION FOR HABEAS CORPUS
Docket Number: RSC-CV-8627
The Respondent, dannydoesapprove, 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 because the
Respondent is sued in the wrong capacity.
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 19, 2026, Petitioner was pulled over by a Ridgeway State Trooper for running
a stop sign. During the stop, Petitioner taunted the Respondent about dying earlier in
front of him.
2. A nearby peace officer warned Petitioner to not honk. It is undisputed that Petitioner had
received prior warnings from various peace officers about misusing his horn.
3. After receiving a citation, Petitioner got back into his truck and immediately honked his
horn.
4. Petitioner told Respondent to arrest him. Respondent pulled Petitioner out of his car, and
arrested him for Excessive Noise Pollution, contrary to R.V.C. § 9.04.
5. However, Petitioner claims that he was actually arrested for violating “RVC § 1.03”, and
that the Respondent is actually an officer of the Ridgeway State Police.
6. Many of Petitioner's claims are legally false, or just outright impossible.
ARGUMENT
I. PETITIONER DOESN’T CHALLENGE CRIMINAL SPEEDING
7. Petitioner alleges he was arrested for violating RVC § 1.03 - Criminal Speeding.
8. Petitioner was not arrested on August 19, 2026, for criminal speeding.
9. Therefore, he cannot possibly expunge a record for which he does not have.
10. Accordingly, the Petition should be denied in its entirety.1
1 The most plausible explanation is that Petitioner misunderstands Ridgeway Vehicle Code. Nonetheless,
they filed and the Respondent must respond.
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RESPONDENT’S BRIEF IN OPPOSITION
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II. THE PETITION FAILS THE ZACHCASISBEAST TEST AND MUST BE
DISMISSED
11. Every Petition for Habeas Corpus in the State of Ridgeway is subjected to the
Zachcasisbeast test. See IamOnCane v. RokuTitanite, RSC-CV-8569.
12. 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.”
13. 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.”
14. Here, the first question is whether the Respondent made a lawful arrest for Excessive
Noise Pollution. A person can be arrested for violating R.V.C. § 9.04 if they repeatedly
honk their horn, and do not stop after being warned by a peace officer. In Respondent’s
probable cause statement, he states that Petitioner was driving around Sterling while
repeatedly honking his horn, and was told to stop. Petitioner admits to honking his horn
again in front of the Respondent, which caused his arrest. In-fact, the evidence shows a
second officer also warn Petitioner not to honk his horn, before he does it again.
Therefore, the arrest was lawful because Petitioner repeatedly honked his horn after being
warned by two officers.
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RESPONDENT’S BRIEF IN OPPOSITION
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15. The second question is whether Petitoner is actually innocent of the offense.
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.”
16. The evidence provided by Petitioner is altered. The length of Petitioner's video is 1m16s
long, but Medal.TV only allows for clips to be recorded in incriminates of 30s, 1m, 2m,
etc. Therefore, the video is cut short.
17. Petitioner claims he doesn’t have the rest of the footage, but fills in the gaps with his own
arguments. Therefore, this evidence could not be admissible, and the facts could not be
relied upon.
18. Furthermore, what remains in the video shows Petitioner being warned by another officer
not to honk, before doing it again. Any well-informed and reasonable jury would believe
he was warned, and did honk. This is corroborated with Petitioner's own statements,
admitting he honked again.
III. PETITONER HAS INTENTIONALLY ALTERED EVIDENCE
19. As discussed in paragraph 16, the Petitioner has provided altered evidence. This should
be a reason for the Court to dismiss the claim.
20. The statement of the Respondent and what Petitioner says does not match. Respondent
claims he was driving around earlier while repeatedly honking, and got warned.
21. That is why Petitioner altered his video, and why half the Petition is about an irrelevant
traffic stop. Petitioner is trying to mislead the Court by framing this as a first-time
encounter.
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RESPONDENT’S BRIEF IN OPPOSITION
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CONCLUSION
22. The Petition fails under the Zachcasisbeast, his own evidence, and his arguments.
23. 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.
24. The Petitioner has intentionally altered the evidence to mislead the Court. Even his own
altered evidence shows other officers warning Petitioner not to honk, before doing it
again.
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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