IN THE SUPERIOR COURT OF THE
STATE OF RIDGEWAY
TAKOSII0,
Petitioner,
v,
LARKIN_RBLX, 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-8446
The Respondent, Larkin_RBLX, 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.
In support of these grounds, a brief in opposition is attached hereto.
FACTUAL BACKGROUND
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RESPONDENT’S BRIEF IN OPPOSITION
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1. On August 19, 2026, the Petitioner was arrested by Respondent for Criminal Speeding,
contrary to R.V.C. § 1.03.
2. Respondent provided a probable cause statement upon arrest, which reads: “Palmer /
Subject was operating his commercial vehicle in george tunnel at 90 SPS in a posted 70
SPS / George Tunnel”
3. Petitioner was detained for 10 minutes.
ARGUMENT
I. PETITION DOESN’T ACTUALLY CHALLENGE THE LEGALITY OF AN
ARREST
4. Petitioner doesn’t actually argue that his arrest was unlawful. Instead, he complains about
how long he was imprisoned for.
5. In IamOnCane v. RokuTitanite, the Court held that the purpose of a habeas corpus is to
challenge the arrest, and that “any such deprivation (of rights) should be pursued through
ordinary civil proceedings.”
6. Because Petitioner doesn’t challenge the arrest, but argues a deprivation of his rights, the
Petition should be denied.
II. 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.
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RESPONDENT’S BRIEF IN OPPOSITION
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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 for Criminal
Speeding, which is defined as any person who operates a motor vehicle at 20 SPS or
more than the posted limit. Respondent arrested Petitioner for driving 90 SPS in a 70 SPS
zone. Some basic math would show that this is 20 SPS over the limit. Because Petitioner
doesn’t even challenge the arrest, and because Respondent observed him at 20 SPS over
the limit, the arrest is lawful.
11. The second question is whether Petitioner 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.”
12. Petitioner does not provide any evidence which might show him being innocent of this
offense. This Court cannot guess what his evidence may be.
13. Ridgeway State Troopers are trained in two ways to enforce speeding. Radar and pacing.
A peace officer cannot charge someone for criminal speeding without actually knowing
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RESPONDENT’S BRIEF IN OPPOSITION
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what speed they were going at. They are trained to determine this speed using either a
radar, or pacing the suspect vehicle (following them to match their speed, in order to
determine a threshold).
14. A reasonable, well-informed jury who is shown either a radar or evidence of pacing
would likely not find Respondent innocent of criminal speeding.
15. Accordingly, Petitioner's claim does not survive the test.
CONCLUSION
16. The Petition fails under the Zachcasisbeast, because the arrest was lawful, and because a
well-informed jury would not find him innocent of criminal speed.
17. The Petitioner doesn’t even challenge the legality of the arrest, instead complains about
how long he was in jail for. A petition for habeas corpus is improper, and he should
instead pursue it through civil court.
18. Because the Petitioner himself doesn’t even challenge the arrest, there is no controversy
for the Court to rule on.
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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