On Point

OLR v. Peter J. Kovac, 2024AP1511-D, 8/15/25, per curiam decision of the Wisconsin Supreme Court (in its disciplinary capacity).

In a decision overlapping with our focus on criminal appeals, SCOW revokes the license of a criminal defense attorney whose misconduct covers both trial and postconviction representation of two clients.

Grant County v. T.L.M., 2025AP500, 8/28/25, District IV (ineligible for publication); case activity

T.L.M. challenges her recommitment, arguing that the circuit court erroneously admitted hearsay evidence over her objection, and that the court failed to make the required factual findings to support the commitment. COA concludes that although the circuit court erroneously admitted some hearsay, the error was harmless, and that the circuit court satisfied the demands of Langlade County v. D.J.W., 2020 WI 41, 391 Wis. 2d 231, 942 N.W.2d 277.

State v. Michael R. Meton, 2025AP141-CR, 8/27/25, District II (one-judge decision; ineligible for publication); case activity

Meton challenges the judgment convicting him of operating with a prohibited alcohol content, 2nd offense. He argues that the circuit court erred in denying his motion to suppress the blood result after police administered a preliminary breath test without first asking for his consent. COA agrees with the circuit court that suppression of the blood draw because police had independent grounds apart from the PBT to arrest Meton on suspicion of operating while intoxicated.

State v. Rebecca Lea Kamm, 2024AP1944-CR, 8/28/25, District IV (ineligible for publication); case activity

The COA held that the defendant forfeited her argument that the State did not comply with Wis. Stat. § 971.23(1) by not disclosing to her counsel video evidence within a reasonable time before trial.  Although the evidence was not provided to counsel until the morning of trial, the issue was forfeited because counsel did not object to its admission.

Brown County v. M.J., 2025AP116, 8/26/25, District III (ineligible for publication); case activity

In a Chapter 51 appeal presenting familiar legal challenges, COA avoids some of the stickier legal issues on a path toward affirmance.

State of Wisconsin v. S.L.L., 2024AP551, 8/26/25, District I (ineligible for publication); case activity

S.L.L. failed to preserve an objection to a protective order as to the identity of the proposed adoptive resource, leading to a quick affirmance from COA.

Wood County v. J.A.B., 2025AP220, 8/21/25, District IV (ineligible for publication); case activity

The COA reversed the circuit court’s order for protective placement because the County did not establish that J.A.B. was so totally incapable of providing for her own care as to create a substantial risk of serious harm to herself or others.

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.

Crawford County v. M.W., 2025AP302, 8/14/25, District IV (ineligible for publication); case activity

Despite concluding that M.W.’s plea colloquy was “lacking in certain respects” on the circuit court’s part, COA holds that the record supports the court’s postdisposition conclusion that M.W. knowingly, intelligently, and voluntarily entered his admission. COA also rejects M.W.’s arguments that the county failed to establish a factual basis and that trial counsel was ineffective.

State v. John R. Phelan,  2024AP777-CR, 8/14/25, District IV (recommended for publication); case activity

In a very complex analysis of the statutes which empower DNR wardens, COA holds that the warden in this case had authority to seize Phelan for suspected littering, validly detained him after obtaining probable cause that he possessed THC, but violated the law by conducting an investigation into an OWI.