On Point: C. Unpublished Opinions

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.

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.

State v. Jasmine C. Daniels, 2025AP74-CR, 3/31/26, District I (not recommended for publication); case activity

In a citable opinion, COA issues a rare defense win, finding the circuit court’s findings of fact clearly erroneous.

State of Wisconsin v. Brandon L. Strickland, 2024AP2376-CR, 3/17/26, District III (not recommended for publication); case activity

The COA determined that law enforcement’s community caretaking function justified an officer to direct a person out of his vehicle after the officer found the person asleep at the wheel while the car was parked in his driveway.  And because the officer developed reasonable suspicion that the suspect used and possessed a controlled substance and was on probation, the officer lawfully searched the vehicle under Act 79.

State v. Conor Alexander Noble, 2025AP811-CR, 3/11/26, District II (1 judge opinion, ineligible for publication); case activity

COA rejects Noble’s facial unconstitutionality challenge to Wisconsin’s Implied Consent Law (ICL) and affirms the circuit court’s denial of Noble’s motion to suppress the blood draw results for lack of voluntary consent.

Sawyer County Health & Human Services v. D.K., 2025AP2832, 3/12/26, District III (ineligible for publication); case activity

The COA reversed the order terminating “Daniel’s” parental rights after summary judgment was granted at the grounds phase because genuine issues of material fact exist whether the County made reasonable efforts to provide services.

State of Wisconsin v. Jonathon L. Sundermeyer, 2024AP2007-CR, 3/3/26, District III (not recommended for publication); case activity

The COA concludes a defective plea colloquy was not sufficient to collaterally attack the defendant’s prior OWI conviction where the defendant did not establish he was unaware of the potential penalties for his prior conviction.  The COA also determined an officer’s affidavit in support of a blood draw complies with the constitutional requirement for an an affidavit to be supported by oath or affirmation where the officer was not present when the defendant was arrested for operating while intoxicated (OWI) but relied on information from an officer who was present.

Jefferson County DHS v. G.J.J., 2025AP2491, 3/5/26, District IV (ineligible for publication); case activity

While G.J.J. gets closer than most–and his arguments even give COA “pause”–ultimately, the deferential standard of review applicable to dispositional decisions results in affirmance.

Grant County Dept of Social Services v. D.G.N., 2025AP2382, 2/27/26, District IV (ineligible for publication); case activity

In this appeal limited to the validity of an order for the involuntary administration of psychotropic medication in a guardianship case, COA holds that the county failed to meet two of the Wis. Stat. § 55.14(3) requirements.

State of Wisconsin v. Jonathan G. Berbaum, 2025AP1380-CR, 2/25/26, District II (ineligible for publication); case activity

The COA affirmed the circuit court’s order denying the defendant’s motion to suppress the fruits of a traffic stop, which included evidence that led to his conviction for operating a vehicle while intoxicated as a third offense.  The COA found that a witness’s report that a vehicle hit a barrier, combined with the defendant’s erratic driving, provided reasonable suspicion to suspect the driver was operating while intoxicated.