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Ex Post Facto – Noncriminal Disability flowing from prior conviction

Monroe Swan v. Douglas LaFolette, 231 Wis.2d 633, 605 N.W.2d 640 (Ct. App. 1999)

Issue: Whether denial of opportunity to become notary public due to felony conviction violates ex post facto provision.

Holding: Ex post facto clause forbids punishing as crime any act which wasn’t punishable when committed, but laws that merely disadvantage someone don’t; because the plain language of the new notary public provision evinces no intent to punish, it doesn’t offend ex post facto notions. ¶¶6-9.

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