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COA affirms juvenile’s placement at Copper Lake School, rejecting argument that placement was improper until State builds facilities contemplated when Lincoln Hills was closed.
State v. A.A.A., 2024AP2001, 3/12/25, District II (ineligible for publication); case activity COA affirmed the circuit court’s dispositional order placing juvenile in the Serious Juvenile Offender program at Copper Lake School, a Type I juvenile correctional facility for girls. The Court rejected juvenile’s claim that such a placement was not permissible until the State builds […]
- a. Dispositional options
- B. Delinquency proceedings
- C. Unpublished Opinions
- 7. Disposition
- 26. Juvenile proceedings
- 46. WI Court of Appeals
- Uncategorized
March 14, 2025
Seventh Circuit cases for February
February brought a handful of cases potentially relevant to our practice:
SCOW accepts review in two cases focusing on the Fourth Amendment in context of internet surveillance targeting alleged child pornography
State v. Gasper, 2023AP2319, petition for review of a published decision of the court of appeals, granted 3/13/25; case activity State v. Rauch Sharak., 2024AP469-CR, accepting review of a certification, granted 3/13/25; case activity
SCOW accepts review in juvenile appeal seeking suppression of statements given to school resource officer
State v. K.R.C., 2023AP2102, petition for review of an unpublished decision of the court of appeals, granted 3/13/25; case activity In a case that could prove consequential for the rights of juveniles in schools policed by “school resource officers,” SCOW accepts review of a case taking direct aim at the court of appeals’ reading of […]
COA rejects challenges to possession of child porn based on erroneous jury instruction and state’s closing argument
State v. Catherine E. Edwards, 2023AP1042-CR, 3/6/25, District IV (not recommended for publication); case activity Edwards’s appeal focuses on the definition of “lewd exhibition of intimate parts” and the state’s closing arguments as to child pornography. COA rejects Edwards’s arguments on appeal and affirms her convictions for possession of child pornography.
- 1. Appeals
- G. Closing argument
- L. Harmless Error
- 12. Jury instructions/verdict
- 25. Jury
- Uncategorized
March 13, 2025
COA holds that 911 call created “emergency” justifying warrantless entry into home
State v. Ryan D. Wilkie, 2022AP730-CR, 3/11/25, District III (1-judge decision, ineligible for publication); case activity COA rejects Wilkie’s interesting constitutional arguments regarding the authority of law enforcement to enter his home without a warrant and affirms his conviction for obstructing an officer.
- Emergency Aid
- C. Unpublished Opinions
- 3. Elements
- C. Warrant unnecessary
- 4. Community caretaker
- 5. Evidence
- 7. Obstructing/resisting
- H. Ch. 946: Against gov't/admin
- 9. Crimes
- 35. Search & Seizure
- 46. WI Court of Appeals
- Uncategorized
March 12, 2025
7th Circuit denies habeas relief to Wisconsin prisoner by holding it cannot consider new evidence supporting petitioner’s claim
Breion S. Woodson v. Bradley Mlodzik, No. 22-3153, 2/28/25 Although Woodson has new evidence seeming to suggest he was sentenced on the basis of inaccurate information, the complex procedural rules of habeas litigation require affirmance.
March 11, 2025
COA finds police had reasonable suspicion to extend traffic stop to conduct field sobriety tests; reverses suppression order.
State of Wisconsin v. Alex Mark Hagen, 2024AP1180, 3/6/25 District IV (one-judge decision; ineligible for publication); case activity COA reversed the circuit court’s order suppressing evidence of field sobriety tests and their fruits, finding that police had reasonable suspicion to extend a traffic stop to investigate the defendant for operating a vehicle while intoxicated.
- 1. Constitutional issues
- 1. Stops, in general
- 1. Appeals
- a. Field Sobriety Testing
- 2. Traffic stops
- B. Chs. 343-346: Traffic offense
- FSTs
- 3. Evidence
- c. Duration
- C. Unpublished Opinions
- E. Specific motions/hearings
- 6. Test for seizure
- 6. Suppression
- G. Reasonable suspicion
- 9. Crimes
- K. Standards of Review
- 23. Search & seizure
- 30. Pretrial proceedings
- 35. Search & Seizure
- 46. WI Court of Appeals
March 7, 2025
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