On Point: C. Unpublished Opinions

Washington County v. J.E.C.,  2025AP2798, 4/29/26, District II (ineligible for publication); case activity

COA relies on the respondent’s frequent absconding from her group home to find dangerousness and also holds that the existing Ch. 55 order is insufficient to meet J.E.C.’s needs.

Winnebago County v. Michael Jon Potratz, 2025AP1059, 4/29/26, District II (ineligible for publication); case activity

The COA affirmed the circuit court’s order denying the defendant’s motion to suppress the results of his blood draw based on the factors established by SCOW in Artic .

State v. Shawn Clarke Spottswood, 2023AP1763-CR, 4/28/26, District III (ineligible for publication); case activity (including briefs)

Spottswood appeals the circuit court’s denial of his suppression motion after having entered a plea to receiving or concealing stolen property. On appeal, he again challenges the warrantless search of his vehicle, contending that law enforcement lacked reasonable suspicion that he had committed, was committing, or was about to commit an offense sufficient to justify the search under 2013 Wis. Act 79 and WIS. STAT. § 973.09(1d).

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.

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.

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.

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.

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.

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.

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.