On Point

It’s September, so that leaves us asking the usual question: What happened to the summer? It turns out that July and August were busy months for the Seventh, so we’ll be updating readers in two installments. We will also be posting separately on the big defense win with respect to AI child porn. This installment features discussion of whether those previously involuntarily committed can possess guns, the contractual interpretation of plea bargains, and a smattering of Fourth Amendment cases.

Rhiannon M. Stroede v. Jason R. Royal, 2025AP2654, 9/3/26, District IV (not recommended for publication); case activity

The COA held that an order terminating a parent’s rights to a child automatically terminates the parent’s obligation to pay child support and the parent is entitled to be reimbursed for any overpayments.

State v. Deonte D. Anderson, 2025AP1309 & 2025AP1310, 9/2/26, District II (not recommended for publication); case activity

The COA affirmed the circuit court’s order denying the defendant’s petition for conditional release from a commitment entered after he was found not guilty by reason of mental disease or defect.  Although the defendant no longer suffered from a mental illness and had not engaged in violence for four years, his poor behavioral record at the Mendota Mental Health Institute was sufficient evidence to deny the petition.

State v. Antwon C. Powell, 2024AP2551, 8/25/26, District III (not recommended for publication); case activity

The COA held that a circuit court may rely on a victim’s life expectancy to set an eligibility date for extended supervision, provided life expectancy is relevant to the primary sentencing factors.

State v. Y.M., 2026AP1212, 8/27/26, District I (ineligible for publication); case activity

“Yolanda” challenges the circuit court’s exercise of discretion at disposition, arguing that the evidence lacked “complete and meaningful testimony” from the children’s foster placements and potential adoptive parents. COA rejects these arguments and affirms.

State v. Paula Andrea Champion, 2025AP802, 8/18/26, District I (ineligible for publication); case activity

COA affirms circuit court’s denial of Paula Champion’s motion to suppress in appeal of PAC 1st judgment.

Lincoln County v. Kayla J. Ristau, 2024AP404, 8/25/26, District III (ineligible for publication); case activity

In a case interpreting a common scenario for some practitioners handling first offense OWIs, COA clarifies the ability of the circuit court to hold a defendant in default for nonappearance and reverses this default order.

State v. Angela R. Joski, 2023AP001371-CR, petition for review of a published decision of the court of appeals, granted 8/18/25; case activity

In a case that could call for an abrupt reassessment of very recent COA precedent, SCOW has indicated its willingness to assess the ability of persons convicted of certain OWI offenses to obtain early release.

Door County v. R.A.W., 2026AP83, 8/18/26, District III (ineligible for publication); case activity

The COA affirmed the appellant’s protective placement in a 24-hour community based residential facility because evidence from the initial hearing and hearing to continue protective placement was sufficient to show that the current placement was the least restrictive in light of the appellant’s need for medication management and 24-hour supervision.

State v. Jeremy Kris Pool, 2025AP1228, 8/20/26, District IV (ineligible for publication); case activity

In a rare case where COA opts to critique and then ultimately reject the factual findings of the circuit court, COA concludes the lower court erred in determining Pool’s speed. It rejects his argument that the citation was improperly amended during the trial.