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L. Harmless Error

State v. Catherine E. Edwards, 2023AP1042-CR, 3/6/25, District IV (not recommended for publication); case activity Edwards’s appeal focuses on the definition of “lewd exhibition of intimate parts” and the state’s closing arguments as to child pornography. COA rejects Edwards’s arguments on appeal and affirms her convictions for possession of child pornography. The state charged Edwards… Read more

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State v. A.M.N., 2024AP440-CR, 3/4/25, District III (1-judge decision, ineligible for publication); case activity While the State concedes that A.M.N.’s statutory right to appear in person for a competency hearing was violated, COA finds the error harmless and affirms. After “Aiden” was charged with two misdemeanors, the circuit court sua sponte raised the issue of… Read more

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State v. K.R.W., 2024AP1210, 2/19/25, District II (one-judge decision; ineligible for publication); case activity Although COA does not address K.R.W.’s broader constitutional argument, it holds that suppression is warranted given the State’s violation of a statute requiring an intake worker to warn a juvenile of his right to counsel and right against self-incrimination before taking… Read more

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Racine County v. C.D.B., 2024AP1195, 2/5/25, District II (1-judge decision, ineligible for publication); case activity In “Banks’s” most recent appeal, he once again challenges the sufficiency of the evidence pertaining to his extension and medication orders. Like his last appeal, however, those arguments go nowhere. Less than a year ago, we posted on “Banks’s” challenge… Read more

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Sheboygan County DH&HS v. A.W., Sr., 2024AP907, District II, 10/30/24 (one-judge decision; ineligible for publication); case activity The COA rejects A.W., Sr.’s claims that the circuit court failed to take testimony to support the finding of unfitness when he pled no contest to grounds, and that the court’s decision to terminate his parental rights at… Read more

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State v. K.R.C., 2023AP2102, 10/30/24, District II (1-judge decision, ineligible for publication); case activity In a “close” suppression appeal, COA confronts a fact pattern arising from the intersection between policing and school discipline, finds that a reasonable 12-year old would have felt free to walk away from interviews with law enforcement and school authorities on… Read more

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A.K.B. v. J.J.G., 2024AP1116, 10/9/24, District II (one-judge decision; ineligible for publication); case activity “Jay” appeals from orders terminating his parental rights and denying his postdisposition motion, arguing the circuit court erroneously exercised its discretion when it terminated his parental rights under the voluntary termination statute, Wis. Stat. § 48.41, rather than applying the hearing… Read more

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Waukesha County v. G.M.M., 2023AP1359, 3/13/24, District II (one-judge decision; ineligible for publication); case activity In an appeal presenting a straightforward D.J.W. claim, COA affirms while also giving credence to harmless error arguments. This is an appeal from G.M.M.’s second 51 extension order. (¶2). The circuit court granted the County’s petition after a contested hearing, finding that… Read more

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