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a. Field Sobriety Testing

State v. Jonah Michael Hoffman, 2024AP1221-CR, 4/24/25, District IV (1-judge decision, ineligible for publication); case activity The sole issue on appeal is whether the deputy who arrested Hoffman had probable cause to search his truck for evidence of an open container. COA concludes that probable cause was lacking, and accordingly reverses and remands with directions… Read more

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State v. Danny Thomas McClain, Jr., 2024AP8, 4/8/25 District I (one-judge decision; ineligible for publication); case activity (including briefs) COA affirms the circuit court’s order denying suppression of the evidence (field sobriety tests and preliminary breathalyzer tests), finding that police had reasonable suspicion to extend a traffic stop to investigate the defendant for additional criminal… Read more

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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. A… Read more

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State v. Emily Anne Ertl, 2023AP234-CR, 2/18/25, District III (one-judge decision; ineligible for publication); case activity Ertl appeals the denial of her motion to suppress on the ground that police impermissibly extended the scope of her initial detention when the officer asked her if she would consent to field sobriety tests. COA affirms, concluding that… Read more

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State v. Lavelle Edgar Young, 2024AP470, 12/26/24, District I (one-judge decision; ineligible for publication); case activity The Court of Appeals affirmed the circuit court’s order denying Lavelle Young’s motion to suppress physical evidence and his statements when an officer knocked on the window of his vehicle after observing Young sleeping in the driver’s seat of… Read more

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State v. Joseph Blankenship, 2024AP791-CR, 11/7/24, District IV (one judge decision; not eligible for publication); case activity The Court of Appeals affirmed the circuit court’s order granting Joseph Blankenship’s motion to suppress because police did not have reasonable suspicion to direct him out of his vehicle to perform field sobriety tests. At 11:30 p.m., Muscoda… Read more

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State v. Reichert, 2023AP1224, 8/14/24, District II (one-judge decision; ineligible for publication); case activity Roxanne Reichert appealed from a judgment of conviction after she pled no contest to operating a vehicle under the influence.  She argued that the circuit court erred when it denied her motion to suppress evidence seized after she was stopped in… Read more

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State v. Iain A. Johnson, 2022AP389-CR, 4/2/24, District III (1-judge decision, ineligible for publication); case activity Although COA concedes this is a “close case,” it nevertheless concludes that the evidence satisfies the relatively low burden for reasonable suspicion to extend a traffic stop. This police contact began when they received a “driving complaint” about Johnson’s… Read more

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