a. Field Sobriety Testing

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

City of West Bend v. Logan Patrick Lang, 2024AP2559, District II, 6/4/25 (one-judge decision; ineligible for publication); case activity COA affirms the circuit court’s order denying Lang’s suppression motion. Lang did not challenge the initial stop, but argued that the officer lacked reasonable suspicion to extend the stop for field sobriety tests. At the suppression… Read more

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

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

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

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

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