Explore in-depth analysis
On Point is a judicial analysis blog written by members of the Wisconsin State Public Defenders. It includes cases from the Wisconsin Court of Appeals, Supreme Court of Wisconsin, and the Supreme Court of the United States.
COA finds that “impossibility” is not a defense to failure to assume a parental relationship; affirms TPR
State v. K.T.R., 2026AP929, 10/14/26, District II (ineligible for publication); case activity
COA holds that the jury’s “impossibility” finding with respect to the continuing CHIPS allegation does not “carry over” to the failure to assume ground and affirms an order terminating parental rights.
SCOW to decide whether circuit court loses competency to continue protective placement when the County does not comply with statutory deadline to file petition and report for annual review.
Milwaukee County Department on Aging v. J.J., 2024AP1850, petition for review of a published court of appeals decision, granted 10/14/26; case activity
SCOW will decide whether the circuit court loses competency to continue protective placement when the County does not comply with the deadline to file a petition and report for annual review.
COA affirms dismissal without prejudice where State did not comply with Interstate Agreement on Detainers.
State v. Larry J. Rush, 2024AP522, 10/6/26, District III (ineligible for publication); case activity
The COA affirmed the circuit court’s order dismissing three misdemeanor charges without prejudice when the State did not comply with the Interstate Agreement on Detainers.
In decision recommended for publication, COA holds that investigating criminal record of a passenger is part of traffic stop “mission”
State v. Erik Howard Pantle, 2025AP2003-CR, 10/14/26, District II (recommended for publication); case activity
In a decision recommended for publication, COA reiterates that a dog sniff is not a search and that police do not unreasonably prolong a traffic stop by running a record check on the passengers in the car.
COA affirms denial of motion to suppress search of individual based on K9’s alert to driver’s car door
State v. Alan Joseph Lecher, 2026AP90-CR, 10/7/26, District II (ineligible for publication); case activity
COA affirms circuit court’s denial of Lecher’s motion to suppress law enforcement’s discovery of alprazolam tablets after a warrantless search, concluding that probable cause existed to search Lecher’s person.
COA holds that circuit court did not erroneously exercise discretion in refusing to reopen forfeiture case
Village of Whitefish Bay v. Ross Bolingbroke, 2025AP2547-52, 10/15/26, District I (ineligible for publication); case activity
COA affirms the court’s ruling that Bolingbroke’s audio-only Zoom appearance merited a default judgment and determines that medical evidence provided by Bolingbroke did not justify reopening the matter after a second missed court date.
COA rejects medley of challenges to Chapter 51 and affirms
Kenosha County v. R.M.P., 2026AP336, 10/7/26, District II (ineligible for publication); case activity
COA rejects “Ronald’s” attempts to overturn his commitment order based on his claims that the court denied his right to self-representation, held the hearing outside of the statutory timeframe, and that the evidence was insufficient.
Defense win: COA reverses protective placement due to insufficient evidence of condition causing incapacity
Calumet County v. S.A., 2026AP1076, 10/7/26, District II (ineligible for publication); case activity
COA reverses S.A.’s protective placement, concluding that the county failed to present sufficient evidence that her incapacity is a result of developmental disability, degenerative brain disorder,
serious and persistent mental illness, or other like incapacities.
COA rejects attempt to distinguish SCOW precedent and finds dangerousness in Ch. 51
Washington County v. P.B.T., 2026AP1230, 9/23/26, District II (ineligible for publication); case activity
Although P.B.T. tries to argue that the plain text of the statute precluded a finding of dangerousness, COA finds his argument foreclosed by existing precedent interpreting that statute and affirms.
COA rejects multiple challenges to appointment of guardian for child
Monroe County v. T.L.B., 2025AP2519, 9/24/26, District IV (ineligible for publication); case activity
T.L.B. appeals an order appointing a guardian of the person for her minor child, G.L.W., under WIS. STAT. § 48.977. She makes numerous arguments, including that the circuit court applied the incorrect legal standard and that its conclusions were erroneous. COA affirms.
Important Posts
Sign up
On Point is sponsored by Wisconsin State Public Defenders. All content is subject to public disclosure. Comments are moderated. If you have questions about this blog, please email [email protected].
On Point provides information (not legal advice) about important developments in the law. Please note that this information may not be up to date. Viewing this blog does not create an attorney-client relationship with the Wisconsin State Public Defender. Readers should consult an attorney for their legal needs.