Justia Wisconsin Supreme Court Opinion Summaries
Gister v. Am. Family Mut. Ins. Co.
In this case the Supreme Court was asked to decide whether a charitable hospital may pursue payment for medical care provided to a Medicaid-eligible patient by filing a lien against a settlement between the patient and an insurance company covering the liability of a tortfeasor responsible for the patient's injuries. To answer the question, the Court balanced the complex state and federal legal framework surrounding Medicaid with Wis. Stat. 779.80 (hospital lien statute). The Court concluded that the soundest harmonization of the two permitted the liens at issue here. In so doing, the Court reversed the court of appeals, which reversed the circuit court's reasoning that the hospital was authorized to either file the liens or bill Medicaid. View "Gister v. Am. Family Mut. Ins. Co." on Justia Law
Adams v. State
The Town of Magnolia granted an application for a livestock facility siting permit submitted by Larson Acres, Inc., but imposed several conditions on the permit. The State Livestock Facilities Siting Review Board affirmed with modifications the permit, determining that certain conditions exceeded the Town's legal authority. The circuit court reversed and remanded the cause to the Siting Board, concluding that the Town acted within its lawful authority when it imposed the conditions. The court of appeals reversed. The Supreme Court affirmed, holding that the Town impermissibly conditioned the terms of the siting permit without following the guidelines set forth by the legislature. View "Adams v. State" on Justia Law
Wis. Dolls, LLC v. Town of Dell Prairie
The Town of Dell Prairie, in renewing the Class "B" and "Class B" alcohol beverages licenses (hereinafter "license") of Wisconsin Dolls, reduced the described premises of the license from the entire eight acres of Wisconsin Dolls' resort property to only the Main Bar / Entertainment Building of the resort. The circuit court dismissed Wisconsin Dolls' certiorari action challenging the reduction. The court of appeals affirmed on different grounds, holding that the original license was void because it failed to particularly describe the premises to which it applied. The Supreme Court reversed, holding (1) the original license granted to Wisconsin Dolls was not void due to an insufficient description of the premises; and (2) the Town exceeded its authority when it modified the description of the premises in renewing Wisconsin Dolls' alcohol beverages license, as the Town here did not proceed on a correct theory of law in modifying the license. Remanded to the circuit court to order the Town to restore the premises description to Wisconsin Dolls' former and current alcohol beverages licenses. View "Wis. Dolls, LLC v. Town of Dell Prairie" on Justia Law
Wadzinski v. Auto-Owners Ins. Co.
This case arose from a fatal motorcycle accident in which Steven Wadzinski was struck and killed by an uninsured motorist. Steven's wife, Michelle, sought uninsured motorist (UM) coverage under an umbrella insurance policy that Steven's company carried on him at the time of his death. At issue was the meaning of an endorsement to the executive umbrella policy, and whether that endorsement caused contextual ambiguity such that a reasonable insured would expect $2,000,000 of UM coverage under the policy. The circuit court held that the executive umbrella policy was clearly intended to provide only third-party liability coverage and granted summary judgment in favor of Auto-Owners Insurance Company. The court of appeals reversed, concluding that the executive umbrella policy was contextually ambiguous, and therefore, the policy should be construed in favor of the insured to afford coverage. The Supreme Court reversed, concluding that the policy at issue unambiguously did not afford first-party UM coverage, and therefore, the circuit court's summary judgment in favor of Auto-Owners was proper. View "Wadzinski v. Auto-Owners Ins. Co." on Justia Law
State v. Ziegler
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. View "State v. Ziegler" on Justia Law
State v. Hunt
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. View "State v. Hunt" on Justia Law
Estate of Kriefall v. Sizzler USA Franchise, Inc.
The questions before the Supreme Court in this case stemmed from damages sustained because of food contaminated by E. coli pathogens at two Sizzler Steak House restaurants. The plaintiffs in the underlying actions settled years ago, and the claims before the Court related to the apportionment of liability and costs among those who were defendants in the underlying actions. The defendants included Sizzler and Excel corporation, which processed and distributed the contaminated meat that was source of the E. coli pathogens. Among the plaintiffs was the estate of Brianna Kreifall, who died from the contaminated food. The court of appeals affirmed in part and reversed in part the circuit court. The Supreme Court affirmed on all issues, holding, inter alia, that (1) Sizzler was entitled to recover consequential damages for Excel's breach of implied warranties in the parties' meat supply contract; (2) Sizzler was entitled to indemnity from Excel for the entirety of Sizzler's advance partial payment to the Kriefall family; and (3) notwithstanding the jury's determination that Sizzler was zero percent responsible for the E. coli contaminated food, Sizzler may not recover attorney fees from Excel because the exception to the American Rule did not apply here. View "Estate of Kriefall v. Sizzler USA Franchise, Inc." on Justia Law
Weborg v. Jenny
After William Weborg died of severe coronary artery disease, his wife and their minor sons (collectively, the Weborgs) commenced a medical malpractice action against three physicians, their insurer, and the Injured Patients and Families Compensation Fund (collectively, the physicians), claiming that the three physicians were negligent in their care and treatment of William, resulting in his death. The jury returned a verdict in favor of the physicians, and the circuit court dismissed the Weborgs' complaint against the physicians. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the circuit court applied an improper legal standard in admitting the evidence of life insurance proceeds and social security benefits, but the error was harmless; and (2) the circuit court erroneously exercised its discretion in modifying the standard jury instruction on expert testimony, but the error was harmless. View "Weborg v. Jenny" on Justia Law
State v. Cain
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. View "State v. Cain" on Justia Law
Milwaukee Journal Sentinel v. City of Milwaukee
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. View "Milwaukee Journal Sentinel v. City of Milwaukee" on Justia Law
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Constitutional Law, Wisconsin Supreme Court