No. 20-7039

Thomas Patrick Keelan v. United States

Lower Court: Eleventh Circuit
Docketed: 2021-02-05
Status: Denied
Type: IFP
Response WaivedIFP
Tags: brady-rule brady-violation criminal-procedure due-process giglio-impeachment giglio-rule homosexuality jencks-act new-evidence perjured-testimony
Latest Conference: 2021-03-05
Question Presented (from Petition)

1. Does an overview of facts collected at trial/ sentencing/
restitution/ direct and collateral review/ (and from startling
new evidence)/ which exposes violations of Jencks/ Brady/ and
Giglio (knowing use of perjured testimony) "put the whole case
in such a different light as to undermine confidence in the
verdict" (Wearry v. Cain/ 2016)/ even for a homosexual?
(Evidence/ Appendix A: Exhibits)

2. If a police agent manipulates IMPLICIT bias against homosexual
men to assert two highly prejudicial falsehoods to enable the
federal indictment itself/ are the indictment and any
decisions incorporating subsequent the falsehoods
constitutionally invalid?

3. Are statutory rape to stop a suicide/ forcible rape/ and
)
"persuasion/" legally identical for homosexual men? was the
invoking of FRE 412 both procedurally mishandled/ leading to
- accidental falsehood (See #5) and incorrectly applied to a
"persuasion" case?

4. Driving someone to suicide has recently been recognized as
manslaughter in several jurisdictions; does the fact that
J.S.'s family and FDLE Agent Cannon knowingly and
intentionally the defendant for framed "attempted
manslaughter/" (that in truth they they caused/ and he
stopped) constitutionally prejudice the case and require
exposure for the future safety of all gay men, including j.s. ?

5. J. S. was an active homosexual who believed eliciting love from
his (admittedly unusual) choice of partners saved his life.
The district court and court of appeals now claim that J.s.'s
prior sexual activity was known. This means that J. S his • t
family, Agent Cannon, and AUSA Altman knowingly lied to the
grand jury, the trial jury, the sentencing court, the
restitution court, and Hebrew Academy's insurance company.
"expert" Terri Patterson and Keelan's attorneys Even FBI
(Randall and particularly Tony Moss) were fooled by false
s
testimony into brutal homophobic prejudice. Is such a
prejudicial falsehood fatal to a prosecution?

6. The new evidence found in prison (Fort Dix) was so shocking
that Judge Goodman LITERALLY did not SEE clear statements by
Attorney petruzzi in the 2255. Goodman is NOT intentionally
biased; does IMPLICIT bias that makes evidence invisible
constitutionally disqualify a ruling?

7. Judge McAliley's restitution ruling clearly states that gay
male sex itself constitutes "bodily injury. " Must such a
bigoted ruling be overturned in light of Obergefell's
guarantee of equality?

8. The Eleventh Circuit ruling on direct appeal asserts that
SUICIDE for gay men is MENTAL HEALTH, and that happiness for
men is a "precipitous deterioration in mental well
being." Must such a bigoted ruling be overturned in light of
Obergefell's guarantee of equality?gay

9. is the brutal physical and psychological,
homophobic-bas e d and Keelan for other's gain in this case torture of J. S.
civilly and criminally actionable?

Question Presented (AI Summary)

Does an overview of facts collected at trial, sentencing, restitution, direct and collateral review, (and from startling new evidence), which exposes violations of Jencks, Brady, and Giglio (knowing use of perjured testimony) 'put the whole case in such a different light as to undermine confidence in the . . verdict' (Wearry v. Cain, 2016), even for a homosexual?

Docket Entries

2021-03-08
Petition DENIED.
2021-02-18
DISTRIBUTED for Conference of 3/5/2021.
2021-02-10
Waiver of right of respondent United States to respond filed.
2020-12-13
Petition for a writ of certiorari and motion for leave to proceed in forma pauperis filed. (Response due March 8, 2021)

Attorneys

Thomas Keelan
Thomas Patrick Keelan — Petitioner
United States
Elizabeth B. PrelogarActing Solicitor General, Respondent