On Point: C. Unpublished Opinions

State v. Megan E. Zeien, 2023AP1787-CR, 4/24/24, District II (one-judge decision, ineligible for publication); case activity

If you’ve ever wondered whether you have a Bangert claim concerning a circuit court’s failure to “ascertain personally whether a factual basis exists to support [your client’s] plea,” this unpublished but citable decision is worth a read. Unfortunately, the decision is a bit unclear about how exactly the state may seek to establish that Zeien’s pleas were knowing, intelligent, and voluntary at an evidentiary hearing. See Op., ¶¶19, 22.

Kenosha County DC&FS v. M.A.M., 2023AP1643-45, 4/24/24, District II (one-judge decision; ineligible for publication); case activity

In a case demonstrating the difficult hurdles litigants must clear in order to prove deficient performance, COA affirms an underlying order terminating “Mary’s” parental rights.

Marinette County v. C.R.J., 2023AP1695-FT, 4/16/24, District III (one-judge decision; ineligible for publication); case activity

C.R.J. (“Caleb”) challenged his commitment on two fronts: (1) the circuit court’s failure to comply with Langlade County v. D.J.W.’s “specific factual findings” mandate and (2) the county failed to introduce sufficient evidence of dangerousness under either standard. After critiquing the circuit court’s factual findings, the court agrees with Caleb that insufficient evidence existed to involuntarily commit him.

State v. J.S.,, 2024AP180 & 2024AP181, 4/16/24, District I (one-judge decision; ineligible for publication); case activity

On appeal from TPR orders related to her two children, J.S. (“Julia”) raised two issues: whether the circuit court had personal jurisdiction over her and whether the circuit court erred by granting the GAL’s substitution request. The court of appeals makes short work of each argument because Julia forfeited the claims by not first raising either issue in the circuit court.

Winnebago County Department of Human Services v. C.R.Q., II,, 2024AP81, 4/17/24, District II (one-judge decision; ineligible for publication); case activity

In a fact-dependent TPR appeal, “Craig” attacks the circuit court’s discretionary ruling on multiple fronts but fails due to the imposing standard of review.

Brown County Health and Human Services v. R.U., 2024AP45-6 4/16/24, District IV (one-judge decision; ineligible for publication); case activity

In yet another fact-dependent TPR appeal, COA affirms given well-settled (and difficult to overcome) legal standards.

Jackson County Department of Human Services v. I.J.R.,, 2023AP1495-6 4/11/24, District IV (one-judge decision; ineligible for publication); case activity

In yet another beefy TPR appeal presenting multiple issues, COA rejects all of I.J.R.’s arguments and affirms.

State v. Iain A. Johnson, 2022AP389-CR, 4/2/24, District III (1-judge decision, ineligible for publication); case activity

Although COA concedes this is a “close case,” it nevertheless concludes that the evidence satisfies the relatively low burden for reasonable suspicion to extend a traffic stop.

State v. Joan L. Stetzer, 2023AP874-CR, 3/27/24, District II (1-judge decision, ineligible for publication); petition for review granted; affirmed 7/3/25 case activity

In a difficult case demonstrating the stringent nature of Wisconsin’s coercion defense, COA affirms the circuit court’s decision that the defense did not apply to Stetzer’s conduct, notwithstanding a medley of uniquely sympathetic facts.

Racine County v. C.B., 2023AP2018-FT, 3/20/24, District II (one-judge decision; ineligible for publication); case activity

In a factually-specific appeal of a recommitment order, COA rejects all of C.B.’s arguments and affirms.