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State v. Manuel Garcia, 2020 WI App 71, petition to review granted, 1/20/21, affirmed by an evenly divided court, 2021 WI 76; case activity (including briefs) Even if a court suppresses a defendant’s voluntary statement because it was obtained in violation of Miranda v. Arizona, 384 U.S. 436 (1966), the state may use the statement… Read more

State v. Pedro R. Mendoza, III, 2018AP2325-Cr,10/6/20,  District 1 (not recommended for publication); case activity (including briefs) A jury convicted Mendoza of 1st degree recklessly endangering safety and 1st degree endangering safety when he shot into a car occupied by H.V. and M.M.C. Mendoza claimed his trial counsel was ineffective for failing to: (1) seek… Read more

State v. Chanler Lee Guyton, 2019AP1409-CR, District 3, 10/6/20 (not recommended for publication); case activity (including briefs) Guyton told a social worker for a county social services agency that she and four of her colleagues had violated his rights in a CHIPS proceeding regarding his son. He said he would deal with the matter “with… Read more

State v. Sarah J. Katula-Talle, 2019AP1622-CR, District 3, 10/6/20 (one-judge decision; ineligible for publication); case activity (including briefs) A police officer had contact with Katula-Talle while responding to a domestic disturbance call. The department’s standard procedure in those situations is to run a driver’s license and warrant check on everyone the officers have contact with… Read more

Portage County v. E.R.R., 2020AP870-FT, District 4, 10/1/20 (one-judge decision; ineligible for publication); case activity As the supreme court recently emphasized, at a proceeding to extend a ch. 51 commitment, proving dangerousness under § 51.20(1)(am) requires evidence establishing that the person is likely to be dangerous under one of the specific standards in § 51.20(1)(a)2… Read more

On September 30, 2020, the court of appeals ordered publication of the following criminal law related decisions: State v. Morgan E. Geyser, 2020 WI App 58 (adult court didn’t lose jurisdiction over juvenile based on facts at preliminary hearing; Miranda waiver was knowing, voluntary, and intelligent) State v. Jordan Alexander Lickes, 2020 WI App 59… Read more

State v. Jacob Richard Beyer, 2019AP1983, 9/24/20, District 4; case activity (including briefs); certification granted 11/18/20, reversed, 2021 WI 59 Wisconsin courts apply a robust guilty-plea waiver rule: in general, a plea will block a defendant from appealing any issue litigated before the plea. There is one important statutory exception: Wis. Stat. § 971.31(10) entitles… Read more