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Curtis L. Walker v. Dan Cromwell, No. 23-2240, 6/16/25 Despite making a “strong case for relief” that his de-facto life sentence for a homicide committed when he was 17 violated the Eighth Amendment, the Seventh Circuit held that Curtis Walker’s habeas petition could not overcome the heavy burden imposed by 28 U.S.C. § 2254(d) to… Read more

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State v. Scott R. Dachelet, 2023AP970, 6/25/25, District II (recommended for publication); case activity Wisconsin’s seemingly straightforward sentence credit statute – Wis. Stat. § 973.155(1)(a) – is required to accommodate an infinite variety of scenarios.  Here, the COA addressed whether a defendant is entitled to sentence credit on a withheld sentence where probation was revoked… Read more

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Waukesha County v. J.A.K., 2024AP2535, 6/25/25, District II (ineligible for publication); case activity In yet another Chapter 51 appeal, COA rejects the usual arguments and affirms. Evidence of Dangerousness Following recommitment, “Janice” argues the evidence was insufficient to establish she was dangerous. Although COA’s lengthy statement of facts contains many concerning details about Janice’s historical… Read more

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State v. Richard Leo Mathewson, 2022AP2124-CR, 6/17/25, District IV (not recommended for publication); case activity COA holds that prospective juror’s equivocal answers during voir dire regarding bias against defendant charged with sexual assault of a child is not sufficient to overcome presumption that juror is impartial. During voir dire for Richard Mathewson’s trial for repeated… Read more

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State v. Jobert L. Molde, 2025 WI 21, 6/13/25, reversing COA’s authored, unpublished opinion; case activity SCOW considers whether an expert witness violated Haseltine‘s anti-vouching rule when she testified that only around one percent of child sexual assault disclosures are false without offering an opinion on whether the victim in this case was telling the… Read more

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State v. Nelson Holmes, 2024AP1121, District I, 6/17/25 (one-judge decision; ineligible for publication); case activity The COA affirmed Nelson Holmes’ conviction at trial of operating a vehicle under the influence and with a prohibited alcohol concentration, finding that a witness’s statements to a 911 operator were not testimonial and were admissible as present sense  impressions… Read more

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State v. Peter Joseph Idell, 2024AP2230, District I, 6/17/25 (one-judge decision; ineligible for publication); case activity The COA holds that an odor of intoxicants and the driver’s 2009 conviction for OWI established reasonable suspicion to extend stop for expired license plates to investigate OWI. A West Allis police officer stopped Peter Idell for driving a… Read more

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Rivers v. Guerrero, USSC No. 23-1345, 6/12/2025; Scotusblog page (with links to briefs and commentary) A unanimous SCOTUS held that a habeas petitioner’s second filing asserting a new claim for relief, submitted after the district court entered judgment with respect to the first filing but while the first filing was pending on appeal, qualifies as… Read more

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