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7. Sec. 939.05

State v. Steven E. Steffek, 2015AP93-CR, District 2, 7/1/15 (one-judge decision; ineligible for publication); case activity (including briefs) The evidence was sufficient to convict Steffek of endangering safety by negligent handling of a dangerous weapon, § 941.20(1)(a), as a party to the crime, despite the fact there was no evidence that anyone was dodging bullets in a “zone… Read More

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Smith v. U.S., USSC 11-8976, 1/9/13 United States Supreme Court decision, affirming United States v.Moore, 651 F.3d 30 (D.C. Cir. 2011) Conspiracy – burden of proof on defendant’s claim of withdrawal Petitioner’s claim lies at the intersection of a withdrawal defense and a statute-of-limitations defense. He asserts that once he presented evidence that he ended his… Read More

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Guilty Plea Colloquy: Party-to-a-Crime Liability

State v. Calvin L. Brown, 2012 WI 139 (recommended for publication); case activity A guilty plea colloquy need not include an explanation of ptac liability when the defendant directly committed the crime: ¶13      …  Although the trial court did not explain that, by directly committing the La Quinta robbery, Brown was “concerned” in… Read More

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State v. Roshawn Smith, 2012 WI 91, reversing in part, affirming in part unpublished decision; case activity Standard of Review: Sufficiency of Evidence  ¶29  We understand Smith’s central argument regarding the standard of review on the evidentiary question to be summed up in the proposition that a jury verdict of guilt[9] must be reversed on appeal if “[t]he inferences that… Read More

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