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7. Sex offender Registration

On review of a court of appeals certification; case activity (including briefs) Issue: Whether Wis. Stat. § 301.45(5)(b)1, which mandates lifetime sex-offender registration where a person has been convicted of a sex offense “on 2 or more separate occasions,” applies when a person’s only eligible convictions are entered on multiple guilty pleas in the same… Read more

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State v. Corey Rector, 2020AP1213, certification filed 11/24/21; granted 2/16/22; District 2; case activity (including briefs) Issue (from the certification): Whether the plain meaning of “separate occasions” in the sex-offender-registration statute means that the two convictions must have occurred at different times in two separate proceedings so that the qualifying convictions occurred sometime before a… Read more

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State v. James A. Carroll, Jr., 2021AP375, 8/26/21, District 4 (one-judge decision; ineligible for publication); case activity (including briefs) Carroll was charged with second-degree sexual assault; he ultimately took a deal and pleaded to fourth-degree. The circuit court required him to register as a sex offender for 15 years after the end of his supervision… Read more

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State v. C.G., 2021 WI App 11; petition for review granted 4/27; case activity Ella–a pseudonym–was adjudicated delinquent for a sexual assault committed when she was 15. Ella’s legal name is masculine in association; during her juvenile disposition she was transitioning to a female identity. In this appeal she challenges the circuit court’s refusal to… Read more

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State v. Todd N. Triebold, 2021 WI App 13; case activity (including briefs) Triebold was convicted of child sexual assault in Wisconsin and subject to lifetime sex offender registration. He moved to Minnesota and notified the Wisconsin DOC of his address. But he moved again and failed to notify either Wisconsin or Minnesota of his… Read more

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Reducing violent recidivism

MULS Professor Michael O’Hear has a new article out: Managing the Risk of Violent Recidivism: Lessons from Legal Responses to Sexual Offenses. See the abstract below, and click here for the article. Over the course of a generation, American legislatures have quietly adopted an intricate web of measures intended to reduce the risk that individuals… Read more

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State v. Timothy L. Landry, 2017AP1739-CR, 6/6/18, District 2 (1-judge opinion, ineligible for publication); case activity (including briefs) Landry pled to 2 counts of 4th-degree sexual assault and was ordered to comply with §973.048(1m)(a), Wisconsin’s sex offender registry. On appeal, he argued that the trial court had not made the necessary findings or explained its… Read more

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Packingham v. North Carolina, USSC No. 15-1194, 2017 WL 2621313 (June 19, 2017); reversing State v. Packingham, 777 S.E.2d 738 (N.C. 2015); Scotusblog page (including links to briefs and commentary) Lester Packingham was convicted for having sex with a 13 year old when he was 21, and was thus required to register as a sex offender… Read more

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