On Point: C. Warrant unnecessary

State of Wisconsin v. Jorge Luis Perez-Aldape, 2026AP642-CR, 7/29/26, District II (ineligible for publication); case activity

In a unique OWI case, COA relies on SCOW guidance to uphold the circuit court’s order suppressing blood evidence due to a failure to read the person the Informing the Accused Form.

County of Milwaukee v. Troy Michael Tordoer, 2024AP2492, 7/28/26, District I (ineligible for publication); case activity

Although Tordoer claims that he was coerced into consenting to an evidentiary blood draw, COA agrees with the circuit court that Tordoer’s consent was voluntary.

State v. Richard A. Tourtillot, 2024AP1831, 7/7/26, District III (not recommended for publication); case activity

The COA determined the defendant’s consent to a blood draw was voluntary under a since-repealed portion of the Implied Consent Law.

City of Mequon v. Scott Sarver Lindvall, 2025AP1703, 5/13/26, District II (ineligible for publication); case activity

Although Lindvall seizes on the officer’s word choice in discussing the consequences of refusing to consent to an evidentiary blood draw, the Court ultimately finds his arguments unavailing and affirms.

State v. William A. Anderson, 2025AP796, 4/29/26, District II (ineligible for publication); case activity

The COA reversed the circuit court’s order denying the defendant’s motion to suppress because law enforcement’s community caretaker function did not justify seizing a possible witness to a motorcycle accident.

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).

State of Wisconsin v. Brandon L. Strickland, 2024AP2376-CR, 3/17/26, District III (not recommended for publication); case activity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

State v. Brandon J. Taff, 2024AP373, 2/17/26, District III (ineligible for publication); case activity

COA reverses Taff’s conviction on the basis that his warrantless blood draw was not justified by exigent circumstances, and therefore should have been suppressed.