Justia Constitutional Law Opinion Summaries

A jury found Defendant guilty of several crimes stemming from allegations involving four teenage girls. Defendant appealed, challenging his conviction on four grounds. The Supreme Court affirmed the judgment of the circuit court, holding (1) there was sufficient evidence to convict Defendant of interference with child custody; (2) the circuit court did not err in denying Defendant's motion to dismiss five of the seven counts of second-degree sexual assault of a child as multiplicitous in violation of Defendant's constitutional protection against double jeopardy, as the five offenses, while identical in law, were different in fact; (3) the admission at trial of Defendant's mug shot did not deprive Defendant of his right to a fair trial; and (4) the circuit court appropriately exercised its discretion in ordering Defendant to wear a stun belt at trial.

At issue in these two consolidated appeals was whether Wis. Stat. 980 requires the dismissal of a pending commitment petition when the individual subject to the petition is re-incarcerated because of the revocation of parole or extended supervision. This appeal involved two defendants committed under chapter 980 after their parole and extended supervision was revoked. The court of appeals affirmed the circuit court and held that dismissal of a Wis. Stat. 980 proceeding was not required when the subject of the petition is transferred to the custody of the Department of Corrections before a chapter 980 commitment order is entered. The Supreme Court affirmed, holding (1) the State may proceed with a chapter 980 commitment after the revocation of a subject individual's parole or extended supervision; and (2) therefore, both of the chapter 980 commitments at issue in this case were valid.

Defendant entered into a plea agreement with the State in which Defendant pled no contest to manufacturing THC. Based on a plea colloquy, the circuit court determined that the plea was entered knowingly, voluntarily, and intelligently. The circuit court accepted Defendant's plea and placed Defendant on probation for a period of two years. Defendant subsequently filed a motion for post-conviction relief, arguing that he was entitled to withdraw his plea to correct a manifest injustice because did not admit to having more than four marijuana plants at the time of the plea colloquy, but rather admitted to having only four plants. The circuit court denied Defendant's post-conviction motion, determining that Defendant's plea was entered knowingly, intelligently, and voluntarily. The Supreme Court affirmed, holding that the record, when viewed in its totality, did not support withdrawal of Defendant's plea, as Defendant did not meet his burden of showing by clear and convincing evidence that allowing the withdrawal of his no contest plea was necessary to correct a manifest injustice.

This case revolved around public records requests of Milwaukee Journal Sentinel reporters seeking dispatch records and incident reports from the Milwaukee Police Department. The City requested advance payment for copying and staff time spent reviewing and redacting the records. The newspaper and its reporters (Newspaper) refused to pay the requested charges and instead sued the City, seeking judgment compelling the City to release the records without prepayment of any fees assessed for redacting information. The circuit court granted summary judgment to the City on the issue of the fees for redaction. The Supreme Court reversed, holding that, in light of the Wisconsin Public Records Law as well as prior interpretations of the Law by the appellate courts, the City could not charge the Newspaper for the costs, including staff time, of redacting information from requested records.

In this case, an officer conducted a traffic stop of Dimitrius Anagnos's vehicle. Once the vehicle was stopped, the officer determined that Anagnos was intoxicated and arrested him for operating while under the influence of an intoxicant (OWI). The circuit court determined that the traffic stop was unconstitutional and that Anagnos's operating privileges should not have been revoked on account of his refusal to take a chemical test to determine the presence or quantity of alcohol in his blood or breath. The court of appeals affirmed. The Supreme Court reversed, holding (1) the arresting officer pointed to specific and articulable facts, which taken together with rational inferences from those facts, gave rise to the reasonable suspicion necessary for an investigative stop; and (2) because the stop of Anagnos's vehicle was supported by reasonable suspicion, the circuit court erred in concluding that the stop was unconstitutional and that Anagnos was not lawfully placed under arrest. Remanded.

As a result of an investigatory stop and search, police discovered drugs and drug paraphernalia in a vehicle driven by Defendant Joseph Miller. The circuit court denied Miller's motion to suppress the evidence and statement obtained from this stop, and Miller pleaded no contest to possession of between five and fifteen grams of cocaine with intent to distribute as a party to a crime. The court of appeals affirmed. The Supreme Court affirmed, holding that under the totality of the circumstances, police acted reasonably when they conducted an investigatory stop of the vehicle that Miller was driving based on reasonable suspicion that criminal activity was afoot, and therefore, the circuit court did err in denying Miller's motion to suppress.

Defendant was convicted of, inter alia, battery to a police officer, carrying a concealed weapon, and DUI. For the battery conviction, Rowan was sentenced to initial confinement followed by extended supervision. Among the conditions of extended supervision imposed by the sentencing court was the condition that Rowan's person, residence, or vehicle was subject to search for a firearm at any time by any law enforcement officer without probable cause or reasonable suspicion. The Supreme Court affirmed the judgment of the circuit court, holding (1) while the condition the circuit court imposed on Rowan's extended supervision may have impinged on constitutional rights, it did not violate them; and (2) the evidence in regard to Rowan's conviction for battery to a police officer was sufficient to support the conviction.

Defendant Douglas Williams pled no contest to manufacturing THC. Williams appealed the denial of his motion to suppress, asserting that the search warrant that was issued for his home by a circuit court commissioner was invalid as beyond the lawful authority of court commissioners, and that the evidence obtained upon the execution of the warrant should be suppressed. Williams' argued that any exercise of power by unelected persons, such as circuit court commissioners, violated the Wisconsin Constitution. At issue before the Supreme Court was whether Wis. Stat. 757.96(1)(b), which grants specific statutory authority to circuit court commissioners to issue search warrants, was unconstitutional. The Supreme Court affirmed the circuit court's denial of Williams' motion to suppress, holding (1) section 757.69(1)(b) is constitutional, as it does not impermissibly intrude upon the judicial power granted to the courts by Wis. Const. art VII, 2; and (2) therefore, the circuit court commissioner's search warrant was validly issued.

Employee filed state discrimination claims against Employer. Employee first filed her claims with the federal Equal Employment Opportunity Commission (EEOC), which dismissed her claims. In the meantime, Employee filed a civil action in the U.S. district court. Employer moved for summary judgment, claiming that Employee's charge was time-barred because it was received by the EEOC more than 300 days after her demotion. Employee argued that the intake questionnaire she submitted to the EEOC constituted a valid charge and was within the 300-day statutory time period. The U.S. district court granted summary judgment for Employer. Employee's claims later went to the Equal Rights Division (ERD) of the Wisconsin Department of Workforce Development, which found concluded that Employee's claims had merit. An ALJ dismissed the proceeding on the basis of claim preclusion. The Labor and Industry Review Commission (LIRC) affirmed. On remand, the ALJ again dismissed, concluding (1) Employee's claims were untimely, and (2) the doctrine of issue preclusion prevented Employee from relitigating the issue of when her charge was filed with the EEOC. LIRC affirmed. The Supreme Court reversed, holding that applying the doctrine of issue preclusion in this case did not comport with principles of fundamental fairness. Remanded.

Helen E.F. was an 85-year-old woman with Alzheimer's Disease. Helen was transported to the emergency room in the city of Fond du Lac for medical treatment. While there, Helen exhibited agitated and aggressive behavior. A police officer placed Helen under emergency detention pursuant to Wis. Stat. 51.15, and Fond du Lac County initiated a chapter 51 proceeding to involuntarily commit her for treatment. The circuit court eventually granted the petition for Helen's involuntary commitment for up to six months in a locked psychiatric unit. The court of appeals reversed, determining that the primary purpose of chapter 51 was to provide treatment, and because Alzheimer's Disease does not respond to treatment, involuntary commitment under chapter 51 was inappropriate. The Supreme Court affirmed, holding that Helen was more appropriately treated under the provisions of chapter 55, the protective service system, which would allow for her care in a facility more narrowly tailored to her needs and provide her necessary additional process and protections.