On Point: K. Standards of Review

County of Trempealeau v. Layne Perry Stenberg, 2024AP281, 4/21/26, District III (recommended for publication); case activity

Stenberg argues that Wis. Stat. § 343.305(2), Wisconsin’s implied consent law, is unconstitutional, both facially and as applied to him. Specifically, he argues that the implied consent law violates the unconstitutional conditions doctrine by requiring him to “forfeit” his Fourth Amendment right to be free from unreasonable searches for the privilege of operating a motor vehicle on a public highway, and that it violates the least intrusive means test under the Fourth Amendment. COA rejects Stenberg’s arguments.

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.

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.

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.

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.

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.

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.

State v. Tate H. Batson, 2025AP136-CR, 2/12/26, District IV (ineligible for publication); case activity

Although Batson tries his best to poke holes in the judge’s discretionary decision, the deferential standard of review means those arguments uniformly fail.

State v. Jacob T. Thornburg,  2023AP600, 1/21/26, District IV (ineligible for publication); case activity

In an appeal following a bench trial for an alleged violation of the traffic code, COA rejects the pro se appellant’s arguments and affirms.

State v. A.B., Jr.,  2024AP2454-56, 12/16/25, District II (ineligible for publication); case activity

In a rare CHIPS appeal, COA applies the discretionary standard of review and affirms.