On Point: C. Unpublished Opinions

State of Wisconsin v. Gabriela Dominguez, 2025AP2666-CR, 10/21/26, District II (ineligible for publication); case activity

Relying on existing precedent, COA concludes a smell of marijuana from a car in which Dominguez was a passenger established probable cause to arrest.

State v. Roosevelt L. Spencer, 2025AP1256, 10/20/26, District III (not recommended for publication); case activity

The COA affirmed the circuit court’s order granting the defendant’s motion to suppress based on issue preclusion where his motion was granted in a prior case, which was dismissed without prejudice, because the State’s only witness did not appear at the evidentiary hearing.  The COA found the criteria for issue preclusion were established – that the matter was actually litigated previously and that applying issue preclusion comported with principles of fundamental fairness.

Chippewa County v. N.M.E., 2026AP545, 10/13/26, District III (ineligible for publication); case activity

The COA reversed the circuit court’s order granting Chippewa County’s petition for protective placement because the evidence was insufficient to show that “Nora’s” cognitive decline presented a substantial risk of serious and foreseeable harm to her and because protective placement was not the least restrictive environment consistent with her needs.

Rock County Human Services Department v. T.S., 2026AP1628-29, 10/15/26, District IV (ineligible for publication); case activity

Although T.S. presents a medley of interesting legal challenges, COA beats backs those arguments and affirms.

State v. K.T.R., 2026AP929, 10/14/26, District II (ineligible for publication); case activity

COA holds that the jury’s “impossibility” finding with respect to the continuing CHIPS allegation does not “carry over” to the failure to assume ground and affirms an order terminating parental rights.

State v. Larry J. Rush, 2024AP522, 10/6/26, District III (ineligible for publication); case activity

The COA affirmed the circuit court’s order dismissing three misdemeanor charges without prejudice when the State did not comply with the Interstate Agreement on Detainers.

State v. Alan Joseph Lecher, 2026AP90-CR, 10/7/26, District II (ineligible for publication); case activity

COA affirms circuit court’s denial of Lecher’s motion to suppress law enforcement’s discovery of alprazolam tablets after a warrantless search, concluding that probable cause existed to search Lecher’s person.

Village of Whitefish Bay v. Ross Bolingbroke, 2025AP2547-52, 10/15/26, District I (ineligible for publication); case activity

COA affirms the court’s ruling that Bolingbroke’s audio-only Zoom appearance merited a default judgment and determines that medical evidence provided by Bolingbroke did not justify reopening the matter after a second missed court date.

Calumet County v. S.A., 2026AP1076, 10/7/26, District II (ineligible for publication); case activity

COA reverses S.A.’s protective placement, concluding that the county failed to present sufficient evidence that her incapacity is a result of developmental disability, degenerative brain disorder,
serious and persistent mental illness, or other like incapacities.

Washington County v. P.B.T., 2026AP1230, 9/23/26, District II (ineligible for publication); case activity

Although P.B.T. tries to argue that the plain text of the statute precluded a finding of dangerousness, COA finds his argument foreclosed by existing precedent interpreting that statute and affirms.