On Point
View all >COA upholds Act 79 vehicle search where officer seized suspect while performing community caretaking function and subsequently developed reasonable suspicion of drug use
State of Wisconsin v. Brandon L. Strickland, 2024AP2376-CR, 3/17/26, District III (not recommended for publication); case activity
The COA determined that law enforcement’s community caretaking function justified an officer to direct a person out of his vehicle after the officer found the person asleep at the wheel while the car was parked in his driveway. And because the officer developed reasonable suspicion that the suspect used and possessed a controlled substance and was on probation, the officer lawfully searched the vehicle under Act 79.
COA affirms ch. 51 recommitment due to forfeiture of hearsay objection, takes judicial notice of a criminal complaint
Fond du Lac County v. S.R.H., 2025AP2727-FT, 3/18/26, District II (ineligible for publication); case activity
“Seth” challenges the 2025 extension of his ch. 51 commitment, contending that Fond du Lac County failed to introduce clear and convincing evidence to support the conclusion that he is dangerous pursuant to either WIS. STAT. § 51.20(1)(a)2.b. or 51.20(1)(am) and that the circuit court therefore erred in entering the extension order on those grounds. COA affirms.
COA rejects facial challenge to Implied Consent Law; affirms denial of motion to suppress blood results
State v. Conor Alexander Noble, 2025AP811-CR, 3/11/26, District II (1 judge opinion, ineligible for publication); case activity
COA rejects Noble’s facial unconstitutionality challenge to Wisconsin’s Implied Consent Law (ICL) and affirms the circuit court’s denial of Noble’s motion to suppress the blood draw results for lack of voluntary consent.
Defense Wins: COA reverses summary judgment at grounds phase of TPR proceeding.
Sawyer County Health & Human Services v. D.K., 2025AP2832, 3/12/26, District III (ineligible for publication); case activity
The COA reversed the order terminating “Daniel’s” parental rights after summary judgment was granted at the grounds phase because genuine issues of material fact exist whether the County made reasonable efforts to provide services.