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K. Standards of Review

State v. Richard Leo Mathewson, 2022AP2124-CR, 6/17/25, District IV (not recommended for publication); case activity COA holds that prospective juror’s equivocal answers during voir dire regarding bias against defendant charged with sexual assault of a child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. Timothy J. Petrie, 2024AP2629-CR, 6/11/25, District 2, (1-judge opinion, ineligible for publication); case activity (including briefs) Petrie argued the officer lacked probable cause to perform a preliminary breath test (PBT), therefore all evidenced gathered afterward must be suppressed. On appeal, he contends that the circuit court improperly applied the independent source doctrine because… Read more

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State v. Kordell Grady, 2025 WI 22, 6/13/25, affirming COA’s summary disposition order; case activity Although SCOW presumably took this case to clarify the rules of Zoom court–and the oral argument focused intensely on such questions–SCOW ultimately opts to issue a decision which makes no substantive law and denies relief based on what it claims… Read more

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State v. Derek J. Jarvi 2023AP2136-CR, 6/12/25, District IV (not recommended for publication); case activity Despite the State’s efforts to overturn Jarvi’s postconviction win of a new trial, the court of appeals rejects the State’s evidentiary arguments and holds that it failed to prove harmless error in this case. Jarvi was convicted of second-degree sexual… Read more

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State v. Benny Burgos, 2024AP1497-CR, 6/3/25, District I (not recommended for publication); case activity In an interesting appeal presenting questions of statutory construction and appellate jurisdiction, COA uses principles of equity to reach the merits and reverses in Burgos’s favor. Burgos was made eligible for SAP at his original sentencing in 2016. (¶2). He enrolled… Read more

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State v. Johnny Ray Martin, 2023AP603, 5/28/25, District III (1-judge decision, ineligible for publication); case activity COA rejects Martin’s claims that the circuit court erroneously exercised its discretion by denying his attempt to impeach the alleged victim with her prior recantation of a separate incident, and that defense counsel was ineffective by failing to adequately… Read more

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State v. Roger A. Minck, 2022AP2292-CR, 5/28/25, District III (recommended for publication); case activity In a case of first impression, the COA held in a decision recommended for publication that hiding a corpse with intent to conceal a crime under Wis. Stat. § 940.11(2) requires the State to prove the defendant  intended to conceal any… Read more

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State v. Peter J. Long, 2024AP1249-CR, 5/28/25, District II (not recommended for publication); case activity While Long’s appeal presents some superficially interesting legal issues, ultimately COA’s dereference to the circuit court’s underlying factual findings govern the outcome here. “Alice,” called police to report that her mother was being physically attacked by the defendant, Long. (¶2)… Read more

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