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C. Warrant unnecessary

State v. Christopher A. Gore, 2023AP169-CR, 1/7/25, District III (recommended for publication), case activity The Court of Appeals held, in a decision recommended for publication, that Christopher Gore’s consent to a blood draw was voluntary because he was not misinformed about the consequences of refusing to consent, and the officer’s statement that he would seek… Read more

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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

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State v. Kahreem Rashah Wilkins, Sr., 2023AP1385-CR, 10/8/24, District I (not recommended for publication); case activity In a 2-1 decision, the Court of Appeals reversed the circuit court’s order granting Kahreem Wilkins’ motion to suppress evidence seized from his vehicle.  The majority found that Wilkins was not seized when police approached the vehicle and saw… Read more

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State v. Reichert, 2023AP1224, 8/14/24, District II (one-judge decision; ineligible for publication); case activity Roxanne Reichert appealed from a judgment of conviction after she pled no contest to operating a vehicle under the influence.  She argued that the circuit court erred when it denied her motion to suppress evidence seized after she was stopped in… Read more

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State v. Michael Gene Wiskowski, 2024 WI 23, 6/18/24, reversing and remanding an unpublished court of appeals decision; case activity (including briefs) Community caretaking does not allow police to continue seizure after officer resolves purpose for stop unless reasonable suspicion or probable cause developed.  Three justices question continuing validity of Wisconsin’s community caretaking precedent in… Read more

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State v. Joshua L. Thering, 2023AP1253, 1/23/24, District 4 (1-judge decision, not eligible for publication); case activity (including briefs) While the court of appeals agrees the facts in Thering’s case are “similar in significant respects” to the SCOW-approved police encounter in County of Grant v. Vogt, 2014 WI 76, 356 Wis. 2d 343, 850 N.W.2d… Read more

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State v. Wayne L. Timm, 2023AP351, 1/19/24, District 4 (one-judge decision; ineligible for publication); case activity (including briefs) The police thought Timm might be responsible for a string of burglaries in the area, and so were looking out for his vehicle. When an officer spotted it one night, he pulled it over for going 31… Read more

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State v. Michael Gene Wiskowski, 2021AP2105, review of a per curiam court of appeals decision granted 9/26/23; reversed 6/18/24 case activity (including briefs, PFR and response) Issues presented (from the PFR): When the report of a person sleeping in a car while waiting in line at a drive thru is contradicted by the officer’s observation… Read more

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