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Timothy Sean Coogle v. United States
IFP petition · United States Court of Appeals for the Fourth Circuit, No. 26-109 · judgment February 6, 2026
Questions presented
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Whether the statutory gatekeeping function assigned to the courts of appeals under 28 U.S.C. § 2244(b) is satisfied when the court issues a rubber-stamp denial that does not address any of the criteria Congress requires for authorizing a successive habeas petition.
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Whether, after Counterman v. Colorado, the First Amendment requires the Government to prove that a defendant charged under 18 U.S.C. § 2422(b) had a subjective intent to persuade, induce, entice, or coerce a minor to engage in unlawful sexual activity, rather than allowing conviction under an objective “reasonable person” standard.
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Whether due process permits a § 2422(b) conviction based on ambiguous online speech that does not clearly establish either the defendant’s subjective intent or a violation of the elements needed to convict.
Counsel of record
For petitioner
Timothy Sean Coogle
For respondent
D. John Sauer
Solicitor General
Case
Conference history
Distributed for 1 conference
Proceedings
- Jun 22 2026Petition DENIED.
- Jun 03 2026DISTRIBUTED for Conference of 6/18/2026.
- May 26 2026Waiver of right of respondent United States to respond filed.
- Mar 25 2026Petition for a writ of certiorari and motion for leave to proceed in forma pauperis filed. (Response due June 1, 2026)