Dane County v. Trent Joseph Meyer, 2024AP1630, 8/14/25, District IV (ineligible for publication); case activity
The COA affirmed a conviction for driving faster than was reasonable and prudent under the conditions where the defendant drove 20 miles-per-hour above the speed limit and came “close” to other cars’ bumpers.
Trent Joseph Meyer was convicted at a bench trial of driving a car faster than was reasonable and prudent under the conditions, contrary to Wis. Stat. § 346.57(2). A Dane County sheriff’s deputy testified that Meyer was driving in the left lane of Highway 12 in Middleton in the late afternoon and approached three cars from behind. The posted speed limit was 55 mph; the deputy estimated Meyer’s speed was 75 mph. As Meyer approached the rear car from behind, he came “close” to the car’s rear bumper. Meyer merged into the right lane ahead of a car in that lane and his rear bumper was “close” to that car’s front bumper. Meyer then accelerated and the deputy paced his speed at 77. The deputy then stopped Meyer and issued a traffic ticket. (¶¶ 2-3).
The Court found sufficient evidence to sustain Meyer’s conviction given that he was traveling more than 20 mph above the speed limit, was close to other vehicles at relevant times, and was near stoplights when he reached his maximum speed. (¶ 11). The Court considered that driving in excess of a posted speed limit, by itself, does not establish a violation of Wis. Stat. § 346.57(2); but the deputy testified that Meyer drove faster than was reasonable and prudent under the conditions given the potential hazards of causing a collision with one of the other cars or requiring another car to swerve or brake. (¶ 12).
Meyer argued that the County did not meet its burden because it did not produce physical evidence, such as the deputy’s dashboard camera footage. But the Court noted that a conviction can be sustained that is not based on “tangible” evidence if the testimony establishes the elements of the offense. (¶ 13).
Meyer also claimed that he was denied due process because he did not have an opportunity to testify and was prevented from showing the circuit court the dashboard camera footage from the deputy. The Court rejected these arguments because the defendant does not have a right to testify at a traffic forfeiture trial and Meyer did not request an opportunity to play the video for the court. (¶¶ 17, 19).