On Point: 2. Traffic stops

Fond du Lac County v. Andrew Joseph Ludwig, 2025AP183, 8/20/25, District II (one-judge decision; ineligible for publication); case activity

Ludwig appeals from a judgment convicting him of OWI 1st, and challenges the order denying his suppression motion. He contends that the sheriff deputies “unconstitutionally detain[ed him]” by failing to conduct the OWI investigation in a sufficiently diligent manner. COA disagrees and affirms.

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.

State v. Timothy J. Petrie, 2024AP2629-CR, 6/11/25, District 2, (1-judge opinion, ineligible for publication); case activity (including briefs)

Petrie argued the officer lacked probable cause to perform a preliminary breath test (PBT), therefore all evidenced gathered afterward must be suppressed. On appeal, he contends that the circuit court improperly applied the independent source doctrine because the state failed to present evidence at the suppression hearing and the court relied on the complaint. COA reverses and remands for an evidentiary hearing on the suppression motion.

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.

State v. Jonah Michael Hoffman, 2024AP1221-CR, 4/24/25, District IV (1-judge decision, ineligible for publication); case activity

The sole issue on appeal is whether the deputy who arrested Hoffman had probable cause to search his truck for evidence of an open container. COA concludes that probable cause was lacking, and accordingly reverses and remands with directions that any evidence derived from the search be suppressed.

State v. Natalie S. Lozano, 2024AP1540-CR & 2024AP1541-CR, 4/9/25, District II (1-judge decision, ineligible for publication); case activity

In yet another appeal hinging on the requirement that a license plate be “legible,” COA affirms based on its deference to the circuit court’s factual findings.

State v. Danny Thomas McClain, Jr., 2024AP8, 4/8/25 District I (one-judge decision; ineligible for publication); case activity (including briefs)

COA affirms the circuit court’s order denying suppression of the evidence (field sobriety tests and preliminary breathalyzer tests), finding that police had reasonable suspicion to extend a traffic stop to investigate the defendant for additional criminal activity.

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.