On Point blog, page 1 of 1

Newly discovered evidence; Juror bias

State v. Daniel Ryan Curry, 2012AP515-CR, District 1, 12/27/12

Court of appeals decision (not recommended for publication); case activity

Newly discovered evidence

Defendant not entitled to new trial based on potentially exculpatory testimony of two witnesses, because the witnesses were known to him before trial. The two witnesses were the son and nephew of a defense witness named Rivera. Statements made by Curry and Rivera and contained in police reports,

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Jury – Selection – Bias / Disqualification – Juror’s Prior Criminal Record

State v. Robert A. Mendoza, 227 Wis.2d 838, 596 N.W.2d 736 (1999), reversing State v. Mendoza 220 Wis.2d 803, 584 N.W.2d 174 (Ct. App. 1998)
For Mendoza: Michael K. Gould, SPD, Milwaukee Appellate

Issue/Holding: Striking jurors (at state’s request) merely because they have criminal records is “an error of law,” ¶24. The court, however, goes on to review whether each such juror should have been struck for cause.

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