On Point: 1. Stops, in general

State of Wisconsin v. Brenda L. Roszina, 2024AP898, 1/13/26, District I (ineligible for publication); case activity

COA affirms the circuit court’s order denying the defendant’s motion to suppress the fruits of field sobriety tests because the investigatory stop did not ripen into an arrest without probable cause when police transported the defendant from a parking lot to the police station one mile away to perform the tests.

State v. Joseph M. Heroff,  2025AP684-CR, 12/23/25, District II (ineligible for publication); case activity

COA applies general reasonable suspicion principles to uphold a stop based on overly dark tint, holding that the officer’s testimony was sufficient and that he did not need to articulate any specific expertise as to the legal tint percentage.

Noem v. Perdomo, USSC No. 25A169, 9/8/2025, Scotusblog page

SCOTUS stayed a district court’s order enjoining immigration agents from conducting stops in the Los Angeles area unless the agent has reasonable suspicion that the person stopped is within the United States in violation of immigration law.

State v. Peter Joseph Idell, 2024AP2230, District I, 6/17/25 (one-judge decision; ineligible for publication); case activity

The COA holds that an odor of intoxicants and the driver’s 2009 conviction for OWI established reasonable suspicion to extend stop for expired license plates to investigate OWI.

City of West Bend v. Logan Patrick Lang, 2024AP2559, District II, 6/4/25 (one-judge decision; ineligible for publication); case activity

COA affirms the circuit court’s order denying Lang’s suppression motion. Lang did not challenge the initial stop, but argued that the officer lacked reasonable suspicion to extend the stop for field sobriety tests.

Isaiah Taylor v. Justin Schwarzhuber, No. 23-3151, 3/17/25

In a rare win, Taylor will have another chance to prove that MPD officers violated his rights when they seized him while he was out delivering a Christmas turkey to a friend.

State v. Jody William Solom, 2024AP691-CR, 3/19/25, District II (recommended for publication), case activity

Solom appeals from a judgment convicting him of operating a motor vehicle while intoxicated (OWI), sixth offense. He asserts the investigative stop was unlawful and should have been suppression. COA disagrees and affirms.

State v. Tobin J. Jagla, 2023AP2311-CR, 3/18/25, District III (not recommended for publication); case activity

COA affirms circuit court’s order denying Tobin Jagla’s motion to suppress where police stopped the vehicle he was driving after an officer determined the registered owner of the vehicle did not have a Wisconsin driver’s license.  Although officer learned during the stop that Jagla was not the registered owner, Jagla and owner were both males and similar in age.

State of Wisconsin v. Alex Mark Hagen, 2024AP1180, 3/6/25 District IV (one-judge decision; ineligible for publication); case activity

COA reversed the circuit court’s order suppressing evidence of field sobriety tests and their fruits, finding that police had reasonable suspicion to extend a traffic stop to investigate the defendant for operating a vehicle while intoxicated.

State v. Glen Michael Braun, 2022AP1764, 2/25/25, District III (one-judge decision; ineligible for publication); case activity

In a case demonstrating the tough hill that litigants must climb to prove an officer lacks reasonable suspicion, COA affirms an order denying Braun’s suppression motion based on a possible equipment violation.