On Point: C. Unpublished Opinions

State v. David T. Waits, 2023AP1592 and 2023AP1593, 12/23/25, District III (ineligible for publication); case activity

The COA affirmed an award of restitution to the victim of a hit and run although the defendant was not allowed to introduce evidence of the victim’s contributory negligence and the victim’s preexisting conditions aggravated her injuries.

State v. Matthew John Flynn, 2024AP2306-CR, 12/17/25, District II (ineligible for publication); case activity

Flynn appeals his operating while intoxicated, third offense, conviction and an order denying his collateral attack motion. He argues that the circuit court erred in denying his motion because he alleged sufficient facts to suggest that the prior conviction did not rest upon a knowing, intelligent, and voluntary waiver of his right to counsel. COA affirms.

Marquette County DHS v. J.J., 2025AP1963, 1964 & 1965, 12/18/25, District IV (ineligible for publication); case activity

J.J. stipulated to the existence of grounds for termination but contested disposition. He now appeals the orders terminating his parental rights to three of his children, arguing that the circuit court erred because it based its termination decision in part on his poverty. COA concludes that the court did not erroneously exercise its discretion and affirms.

Eau Claire County v. R.B.-K., 2025AP1466, 12/16/25, District III (ineligible for publication); case activity

In a “close case,” the COA affirmed continuing protective placement over a challenge to the sufficiency of the evidence that “Rory” was a danger to himself.

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.

State v. Charles Williams, 2024AP1424-CR, 12/2/25, District III (authored, not recommended for publication); case activity

Williams argues that the circuit court erred by denying his postconviction motion to withdraw his plea because he did not knowingly, intelligently, and voluntarily waive his right, under WIS. STAT. § 971.04(1)(g), to appear in person at the plea hearing. COA assumes without deciding that Williams did not waive his right to be present, but concludes that any error was harmless and affirms.

State v. Ryan D. Zimmerman,  2023AP1888-CR, 11/25/25, District III (not recommended for publication); case activity

Although Zimmerman identifies a novel Fourth Amendment issue, COA ultimately uses Zimmerman’s consent to get around that issue and affirms.

State v. Sam M. Shareef, 2025AP661, 12/10/25, District II (ineligible for publication); case activity

The COA holds that police reasonably conveyed implied consent warnings to a suspected drunk driver although the officer told the driver that some of the circumstances described on the Informing the Accused form did not apply to him.

State v. K.R.C., 2025AP90, 12/9/25, District III (one-judge decision; ineligible for publication); case activity

“Kyle” appeals, arguing that the state did not have good cause for filing a delinquency petition outside the 20-day filing deadline in WIS. STAT. § 938.25(2)(a). COA disagrees and affirms.

State v. Billy Ray Edward Johnson, 2024AP1135, 12/2/25, District I (ineligible for publication); case activity

COA reverses order denying State’s motion to admit body camera footage compiled by a deceased police officer.