Supreme Court Report

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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


Certiorari denied · June 22, 2026

Questions presented

  1. 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.

  2. 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.

  3. 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

Subject area
Criminal Procedure (estimated from the questions presented, in the Supreme Court Database’s categories)

Conference history
Distributed for 1 conference

Order
Order list, June 22, 2026 · Certiorari denied

Proceedings

  1. Jun 22 2026
    Petition DENIED.
  2. Jun 03 2026
    DISTRIBUTED for Conference of 6/18/2026.
  3. May 26 2026
    Waiver of right of respondent United States to respond filed.
  4. Mar 25 2026
    Petition for a writ of certiorari and motion for leave to proceed in forma pauperis filed. (Response due June 1, 2026)