On Point blog, page 1 of 120

COA applies J.J., again holds failure to file petition and report doesn’t deprive circuit court of competency

Milwaukee County DHHS Aging and Disability Services v. B.C., 2024AP2521, 4/7/26, District I; case activity

Applying its recent decision published decision in Department on Aging v. J.J., COA again holds that the county’s failure to timely file the required petition and report to initiate the annual review does not deprive the circuit court of competency.

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COA: Restitution properly awarded to disorderly conduct victim where defendant fled in and did not return car jointly owned with victim.

State v. Alexander C. Beaver, 2025AP1768-CR, 4/1/26, District II (ineligible for publication); case activity

The COA affirmed the circuit court’s award of restitution to a disorderly conduct victim where the defendant fled the scene in a vehicle jointly owned by the victim and the defendant and did not return the vehicle.

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SCOW issues powerful decision relevant to juveniles interrogated at school but denies relief under harmless error analysis

State v. K.R.C., 2026 WI 10, 3/26/26, reversing an unpublished decision of the court of appeals; case activity

While SCOW denies relief to K.R.C., it issues a strongly worded decision that will help vindicate the constitutional rights of children interacting with school resource officers on campus.

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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.

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COA rejects challenges to TPR dispositional order and affirms

Jefferson County DHS v. G.J.J., 2025AP2491, 3/5/26, District IV (ineligible for publication); case activity

While G.J.J. gets closer than most–and his arguments even give COA “pause”–ultimately, the deferential standard of review applicable to dispositional decisions results in affirmance.

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COA dismisses appeal for lack of jurisdiction where one count is not “final” due to deferred judgment agreement.

State of Wisconsin v. Gustin J. King, 2024AP2064-CRNM, 2/18/26, District II (recommended for publication) (per curiam); case activity

The COA, in the first published decision on the issue, holds that it does not have jurisdiction to review a judgment of conviction when one or more of the criminal counts is unresolved due to the existence of a deferred judgment agreement (DJA).

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COA holds that costs to investigate crime are recoverable as restitution, but not attorney fees.

State of Wisconsin v. Mary E. Melstrom, 2023AP1176-CR, 2/17/26, District III (ineligible for publication); case activity

The COA affirmed a restitution award to cover the victim insurance company’s costs of investigating the cause of a house fire that was the subject of the defendant’s criminal charge but reversed the award for the victim’s attorney fees.

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Defense win: COA upholds jury’s verdict in favor of TPR respondent

J.R.P. v. W.P.M., 2024AP1535, 2/19/26, District IV (ineligible for publication); case activity

In a rare sufficiency challenge pursued by the petitioner, COA applies a deferential standard of review and affirms.

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COA finds there was sufficient evidence of obstructing and affirms

State v. Kyle R. Appel, 2023AP2083-CR, 2/17/26, District III (ineligible for publication); case activity

Applying a standard of review exceptionally deferential to a jury’s decision to convict, COA distinguishes Appel’s proffered authority and affirms.

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COA rejects challenge to TPR dispositional order and affirms

State v. L.Z., 2025AP2731-32, 2/17/26, District I (ineligible for publication); case activity

Although L.Z. tries to capitalize on certain statements in the court’s oral ruling as giving a foothold for her appellate challenge, the standard of review means the argument attacking a discretionary decision goes nowhere.

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