As usual, we bring you coverage of COA’s orders regarding publication, this time for April, May and June. In April, COA published one case relevant to our practice, State v. Jody William Solom, 2025 WI App 25. The case distinguishes an oft-cited recent defense win, Richey, and holds that officers had reasonable suspicion to conduct a traffic stop… Read more
46. WI Court of Appeals
State v. T.R.T., 2025AP387-CR, 6/19/25, District IV (not recommended for publication); case activity Although it acknowledges uncertainty as to the appropriate standard of review, COA ultimately affirms the circuit court’s order under a clearly erroneous standard. After concerns were raised about T.R.T.’s competency, the circuit court ordered an examination and scheduled a hearing to address… Read more
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 Here, the COA addressed whether a defendant is entitled to sentence credit on a withheld sentence where probation was revoked… Read more
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
State v. Richard Leo Mathewson, 2022AP2124-CR, 6/17/25, District IV (not recommended for publication); case activity COA holds that prospective juror’s equivocal answers during voir dire regarding bias against defendant charged with sexual assault of a child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
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
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
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
