On Point blog, page 1 of 496
COA holds that termination of parental rights automatically terminates the parent’s obligation to pay child support, and the parent is entitled to be reimbursed for overpayments.
Rhiannon M. Stroede v. Jason R. Royal, 2025AP2654, 9/3/26, District IV (not recommended for publication); case activity
The COA held that an order terminating a parent’s rights to a child automatically terminates the parent’s obligation to pay child support and the parent is entitled to be reimbursed for any overpayments.
COA determines misbehavior at mental health facility sufficient to deny conditional release from NGI commitment, although defendant no longer suffers from mental illness and has no recent history of violence.
State v. Deonte D. Anderson, 2025AP1309 & 2025AP1310, 9/2/26, District II (not recommended for publication); case activity
The COA affirmed the circuit court’s order denying the defendant’s petition for conditional release from a commitment entered after he was found not guilty by reason of mental disease or defect. Although the defendant no longer suffered from a mental illness and had not engaged in violence for four years, his poor behavioral record at the Mendota Mental Health Institute was sufficient evidence to deny the petition.
COA: Sentencing court may set eligibility date for extended supervision based on victim’s life expectancy if relevant to a primary sentencing factor.
State v. Antwon C. Powell, 2024AP2551, 8/25/26, District III (not recommended for publication); case activity
The COA held that a circuit court may rely on a victim’s life expectancy to set an eligibility date for extended supervision, provided life expectancy is relevant to the primary sentencing factors.
COA rejects challenge to exercise of discretion at TPR disposition hearing
State v. Y.M., 2026AP1212, 8/27/26, District I (ineligible for publication); case activity
“Yolanda” challenges the circuit court’s exercise of discretion at disposition, arguing that the evidence lacked “complete and meaningful testimony” from the children’s foster placements and potential adoptive parents. COA rejects these arguments and affirms.
COA affirms denial of motion to suppress extension of stop and PBT results
State v. Paula Andrea Champion, 2025AP802, 8/18/26, District I (ineligible for publication); case activity
COA affirms circuit court’s denial of Paula Champion’s motion to suppress in appeal of PAC 1st judgment.
COA clarifies ability of circuit court to enter default order for nonappearance in civil OWI matter
Lincoln County v. Kayla J. Ristau, 2024AP404, 8/25/26, District III (ineligible for publication); case activity
In a case interpreting a common scenario for some practitioners handling first offense OWIs, COA clarifies the ability of the circuit court to hold a defendant in default for nonappearance and reverses this default order.
COA relies on evidence from initial protective placement hearing to conclude current placement least restrictive where there is no evidence condition had changed and some evidence condition had deteriorated.
Door County v. R.A.W., 2026AP83, 8/18/26, District III (ineligible for publication); case activity
The COA affirmed the appellant’s protective placement in a 24-hour community based residential facility because evidence from the initial hearing and hearing to continue protective placement was sufficient to show that the current placement was the least restrictive in light of the appellant’s need for medication management and 24-hour supervision.
COA rejects circuit court’s factual findings in speeding appeal
State v. Jeremy Kris Pool, 2025AP1228, 8/20/26, District IV (ineligible for publication); case activity
In a rare case where COA opts to critique and then ultimately reject the factual findings of the circuit court, COA concludes the lower court erred in determining Pool’s speed. It rejects his argument that the citation was improperly amended during the trial.
COA issues 2nd Amendment decision on gun rights of foster parents
Brian Lafferty and Katie Lafferty v. Jeff Pertl and Julie Driscoll, 2025AP414, 7/31/26, District II (recommended for publication); case activity
In one of the first published Wisconsin cases to apply SCOTUS’s evolving precedent on firearm possession, COA holds that at least some regulations placed on foster parents to limit access to firearms went too far.
COA grants sentence credit claim in authored decision
State v. Matthew Guy O’Dierno, 2025AP1327, 8/6/26, District IV (not recommended for publication); case activity
COA holds that O’Dierno is entitled to sentence credit on new charges for his entire period of pretrial jail custody when a portion of the time was also spent completing a conditional jail sentence.