Justia Wisconsin Supreme Court Opinion Summaries

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. View "State v. Miller" on Justia Law

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. View "State v. Rowan" on Justia Law

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. View "State v. Williams" on Justia Law

The circuit court granted summary judgment to Community Insurance Corporation (CIC) on a claim by the Hartford Union High School Board of Education and the Hartford Union High School District (collectively, the District) that insurance coverage had been created by virtue of CIC's failure to issue a reservation of rights letter during its unsuccessful defense of the District in a contract lawsuit. The court of appeals reversed, holding that CIC was estopped from denying coverage because the District relied on CIC's defense to its detriment and was prejudiced thereby. The Supreme Court reversed, holding that the failure to issue a reservation of rights letter cannot be used to defeat, by waiver or estoppel, a coverage clause in an insurance contract that would otherwise justify the insurer's denial of coverage. View "Maxwell v. Hartford Union High Sch. Dist." on Justia Law

Marco Marquez, the consumer, brought this action against Mercedes-Benz USA, alleging that his new car was a "lemon" under the state's Lemon Law, that he requested a refund and provided Mercedes-Benz with the required notice and information, and that Mercedez-Benz failed to provide a refund within the thirty-day period as required under the Lemon Law. At issue in this case was whether Marquez intentionally thwarted Mercedes-Benz's attempt to provide a refund within the thirty-day statutory period by failing to provide necessary information. On remand, the jury found in favor of Mercedes-Benz, but the circuit court entered a directed verdict in favor of Marquez, finding no credible evidence that Marquez intentionally thwarted Mercedes-Benz's efforts to provide a refund. The Supreme Court affirmed, holding that no credible evidence supported the jury's verdict, and therefore, the circuit court was not clearly wrong in directing the verdict in favor of Marquez. View "Marquez v. Mercedes-Benz USA, LLC" on Justia Law

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. View "Aldrich v. Labor & Ind. Review Comm'n" on Justia Law

The State filed a petition alleging that Tyler T., a juvenile, was delinquent and a petition for waiver of juvenile court jurisdiction over Tyler. The circuit court waived juvenile court jurisdiction over Tyler, and the court of appeals affirmed. Tyler appealed, arguing that the circuit court erred as a matter of law in denying his request to strike a waiver investigation report prepared by the county department of health and human services (DHHS). The DHHS prepared its report after conducting a staffing meeting in which the county assistant district attorney, who filed the petition alleging Tyler's delinquency, participated. Because neither Tyler nor his defense counsel was invited to attend the meeting, Tyler contended that the assistant district attorney's participation in the staffing meeting constituted improper ex parte communication that compromised the objectivity of the waiver investigation report. The Supreme Court affirmed, holding that the circuit court did not err in denying Tyler's request to strike the waiver investigation report prepared by the DHHS, as the DHHS is free to compile information for a waiver investigation report in the manner it deems most beneficial to the circuit court. View "State v. Tyler T." on Justia Law

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. View "Fond du Lac County v. Helen E. F." on Justia Law

After Employee suffered a work-related injury and was terminated by Employer due to Employer's inability to accommodate his physical restrictions, Employee filed a worker's compensation claim for permanent and total disability. The Labor and Industry Review Commission (LIRC) determined that Employee was permanently and totally disabled as a result of his work injury. LIRC made this determination after denying Employer's last-minute request to cross-examine or make further inquires of Dr. Jerome Ebert, an independent physician appointed by the Department of Workforce Development to examine Schaefer and report on the cause of his disability. The court of appeals affirmed. The Supreme Court affirmed, holding (1) Employer did not have a statutory right to cross-examine Dr. Ebert, (2) LIRC did not violate Employer's due process rights when it declined to remand for cross-examination, and (3) LIRC did not erroneously exercise its discretion by declining to remand for a third time to allow Dr. Ebert to be questioned further. View "Aurora Consol. Health Care v. Labor & Indus. Review Comm'n" on Justia Law

The Wisconsin Department of Transportation acquired a parcel of land owned by Country Side, a portion of which Country Side leased to the Lamar Company. Country Side and Lamar agreed that all proceeds would be transferred to Country Side, save for $120,000, of which the parties were unable to agree to a division. Consequently, Lamar filed a claim for petition, seeking the full amount on deposit. Country Side responded by petitioning for the full amount. The circuit court granted Country Side's petition and ordered the $120,000 to be disbursed to Country Side, concluding that Lamar had lost its right to seek a share of the award of damages issued to Country Side and Lamar by failing to join in Country Side's appeal of the award. The court of appeals affirmed. The Supreme Court reversed, holding that Lamar had not lost its right to seek a share of the award of damages issued to Country Side and Lamar, and therefore, the circuit court improperly dismissed Lamar's claim for petition. Remanded. View "Lamar Co., LLC v. Country Side Rest., Inc." on Justia Law