On Point blog, page 1 of 1

COA holds that driver’s odor of alcohol and prior conviction for OWI provides reasonable suspicion to extend traffic stop

State v. Peter Joseph Idell, 2024AP2230, District I, 6/17/25 (one-judge decision; ineligible for publication); case activity

The COA holds that an odor of intoxicants and the driver’s 2009 conviction for OWI established reasonable suspicion to extend stop for expired license plates to investigate OWI.

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Defendant waived trial counsel’s conflict of interest

State v. Michael Wade, 2018AP614-CR, 3/5/19, District 1 (1-judge opinion; ineligible for publication); case activity (including briefs)

Wade challenged his convictions for misdemeanor intimidation of a witness and violating a domestic abuse injunction on the grounds that his trial lawyer had a conflict of interest: he had previously represented the victim in other criminal matters. The court of appeals held that Wade waived the conflict.

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