On Point: L. Harmless Error

State v. Jerome G. Semrau, 2000 WI App 54, 233 Wis. 2d 508, 608 N.W.2d 376
For Semrau: John D. Lubarsky, SPD, Madison Appellate

Issue: Whether (assumed) erroneous refusal to suppress evidence was harmless on appeal following guilty plea, under Wis. Stat. § 971.31(10).

Holding: Strength of admissible evidence, apart from unsuppressed evidence, placed Semrau in “significant risk of conviction,” so that there was no reasonable probability that the suppression ruling caused him to plead guilty,

State v. Tonnie D. Armstrong, 223 Wis.2d 331, 588 N.W.2d 606 (1999), reconsideration denied, 225 Wis.2d 121, 591 N.W.2d 604 (1999)
For Armstrong: Steven A. Koch and Seymour, Kremer, Nommensen, Morrissy & Koch

Issue/Holding: Armstrong pleaded guilty, with suppression issues (admissibility of oral statements) preserved as matter of law under Wis. Stat. § 971.31(10). The supreme court holds that the trial court’s refusal to order suppression was error,