On Point blog, page 4 of 495
COA interprets deferred judgment agreement and finds State was permitted to move to revoke outside of deferral period
State of Wisconsin v. Derrick John Grignon, 2024AP1595-CR, 4/28/26, District III (recommended for publication); case activity
In a decision recommended for publication, COA applies contract law principles to a deferred judgment agreement and finds that the State properly moved to revoke the agreement following Grignon’s noncompliance with its terms.
COA rejects multiple challenges to TPR and affirms
Monroe County Department of Human Services v. A.S., 2026AP65-66, 4/23/26, District I (ineligible for publication); case activity
Although A.S. raises multiple challenges to this TPR, COA uniformly finds her arguments unavailing.
Defense Wins: COA reverses commitment order and order to continue commitment based on insufficient evidence of dangerousness.
Jackson County v. D.C., 2025AP1838 & 2025AP1839, 4/23/26, District IV (ineligible for publication); case activity
The COA reversed D.C.’s commitment order and the order extending his commitment because the County did not meet its burden to establish he was dangerous.
COA determines any error by State commenting at trial on defendant asserting her right to silence was harmless.
State v. Elizabeth A. Erickson, 2025AP1150-CR, 4/22/26, District II (ineligible for publication); case activity
The COA affirmed the defendant’s conviction for disorderly conduct and the circuit court’s order denying the defendant’s motion for postconviction relief alleging her counsel was ineffective for failing to object to the State’s comments at trial that she did not tell police about a dog causing injuries to the victim. The COA did not address whether the State’s comments violated the defendant’s right against self-incrimination, but determined any error was harmless.
Defense win: COA affirms circuit court order for plea withdrawal in yet another TPR burden of proof appeal
State v. D.H., 2025AP2668, 4/10/26, District I (ineligible for publication); case activity
Potentially reviving an issue many may have thought already settled, COA upholds the circuit court’s order for plea withdrawal in a case involving a deficient colloquy regarding the dispositional burden of proof in a TPR case.
COA rejects attempt to apply Cronic to TPR IAC claim and affirms
State v. V.T., 2025AP1338-40, 3/23/26, District I (ineligible for publication); case activity
In an interesting ineffectiveness appeal, COA confronts clear-cut deficient performance but declines V.T.’s invitation to depart from the Strickland prejudice standard.
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.
COA: Defendant not entitled to return of property after he was charged with carrying a firearm where alcohol is sold, but charge was dismissed and read in.
State v. Joseph A. Wheat, 2024AP2369-CR, 4/8/26, District II (ineligible for publication); case activity
The COA held that the defendant was not entitled to have his firearm and ammunition returned to him or sold to a third party for his benefit after they were seized by police when he was charged with carrying a handgun where alcohol is sold and consumed. Although the charge was dismissed and read in, the COA considered the defendant admitted to committing the offense when he agreed to have it dismissed and read in.
COA finds evidence sufficient for Chapter 55 medication order
Winnebago County v. L.J.F.G., 2025AP2645-FT, 4/8/26, District II (ineligible for publication); case activity
In a rare appeal from an involuntary medication order related to a protective placement order, COA affirms despite some of the County’s missteps.
COA: Although plea in TPR appears “questionable,” parent did not prove manifest injustice meriting plea withdrawal
State v. B.A.J., 2025AP1476-77, 4/2/26, District I (ineligible for publication); case activity
In a case that demonstrates the high burden that parents must satisfy to withdraw their pleas, COA affirms despite also acknowledging the “questionable” nature of this mentally ill parent’s plea.