presence factors (Wisconsin) · Go Syfert
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presence factors in Wisconsin

20 Wisconsin opinions name it 2 courts 1923–2024 3 in the last five years

The cases below were cited by Wisconsin courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (9)

CaseFollowedCited
James Richard Ellis v. State of Oklahoma and Warden Ray H. Pagegreen
ca10 · 1970 · cited in 2 Wisconsin opinions naming this issue, 2013–2022
2 sentences

2022We emphasized, "[a]ll that the Constitution requires at such a conference is the presence of defense counsel." Id. (citing Ellis v. Oklahoma, 430 F.2d 1352, 1355 (10th Cir. 1970)) (emphasis added).

2022In this case, defense counsel was present "at such a conference" "concerning dismissal of a juror." See id. ¶38 Prior to the discussion on the juror's dismissal, the judge was notified that a juror was feeling ill and laying down in the jury room, had Juror 2 moved to her chambers where there was "a quiet place for her to rest," proceeded to check on Juror 2 in her chambers——meanwhile "conferr[ing]" with counsel who "agreed to wait"——and asked a question on behalf of defense counsel regarding the nature of the illness.

22
CONTEMPT IN STATE v. Dewerthgreen
wis · 1987 · cited in 3 Wisconsin opinions naming this issue, 1990–1995
2 sentences

1995Court, 154 Wis. 2d 1, 12 , 452 N.W.2d 355 (1990) (citing Dewerth, 139 Wis. 2d at 552 -53 & n.4, 407 N.W.2d 862 ), we held that the actual presence requirement is satisfied when the contumacious act occurs during formal court proceedings.

1995Court, 154 Wis. 2d 1, 12 , 452 N.W.2d 355 (1990) (citing Dewerth, 139 Wis. 2d at 552 -53 & n.4, 407 N.W.2d 862 ), we held that the actual presence requirement is satisfied when the contumacious act occurs during formal court proceedings.

13
United States v. Arvizugreen
scotus · 2002 · cited in 1 Wisconsin opinions naming this issue, 2015–2015
1 sentence

2015See United States v. Arvizu, 534 U.S. 266, 274-75 (2002). ¶37 It follows that the legality of the extension of the traffic stop in this case turns on the presence of factors which, in the aggregate, amount to reasonable suspicion that Hogan committed a crime the investigation of which would be furthered by the defendant's performance of field sobriety tests.

11
State v. Postgreen
wis · 2007 · cited in 1 Wisconsin opinions naming this issue, 2015–2015
2 sentences

2015See State v. Post, 2007 WI 60, ¶ 10 , 301 Wis. 2d 1 , 733 N.W.2d 634 . ¶ 38.

2015See State v. Post, 2007 WI 60, ¶ 10 , 301 Wis. 2d 1 , 733 N.W.2d 634 . ¶ 38.

11
United States v. Barry H. Parentgreen
ca1 · 1992 · cited in 1 Wisconsin opinions naming this issue, 2006–2006
1 sentence

2006ABA Standards for Criminal Justice: Discovery and Trial by Jury Standard 15-5.2(a) (3d ed.1996), available at http://www.abanet.org/crimjust/standards/jurytrial_toc.html (last visited June 22, 2006). [44] United States v. Parent, 954 F.2d 23, 26 (1st Cir.1992).

11
State v. David J.K.green
wisctapp · 1994 · cited in 1 Wisconsin opinions naming this issue, 1998–1998
2 sentences

1998We believe that the correct view of the law, as stated in both State v. McMahon, 186 Wis. 2d 68, 88 , 519 N.W.2d 621, 629 (Ct. App. 1994), and State v. David J.K, 190 Wis. 2d 726, 736 , 528 N.W.2d 434, 439 (Ct. App. 1994), is that a violation of the defendant's right to be present "does not automatically entitle [the defendant] to a new trial; such error may be found to be harmless beyond a reasonable doubt." In McMahon , the court communicated with the jury on five occasions without the defendant's presence or a waiver.

1998We believe that the correct view of the law, as stated in both State v. McMahon, 186 Wis. 2d 68, 88 , 519 N.W.2d 621, 629 (Ct. App. 1994), and State v. David J.K, 190 Wis. 2d 726, 736 , 528 N.W.2d 434, 439 (Ct. App. 1994), is that a violation of the defendant's right to be present "does not automatically entitle [the defendant] to a new trial; such error may be found to be harmless beyond a reasonable doubt." In McMahon , the court communicated with the jury on five occasions without the defendant's presence or a waiver.

11
State v. McMahongreen
wisctapp · 1994 · cited in 1 Wisconsin opinions naming this issue, 1998–1998
2 sentences

1998We believe that the correct view of the law, as stated in both State v. McMahon, 186 Wis. 2d 68, 88 , 519 N.W.2d 621, 629 (Ct. App. 1994), and State v. David J.K, 190 Wis. 2d 726, 736 , 528 N.W.2d 434, 439 (Ct. App. 1994), is that a violation of the defendant's right to be present "does not automatically entitle [the defendant] to a new trial; such error may be found to be harmless beyond a reasonable doubt." In McMahon , the court communicated with the jury on five occasions without the defendant's presence or a waiver.

1998We believe that the correct view of the law, as stated in both State v. McMahon, 186 Wis. 2d 68, 88 , 519 N.W.2d 621, 629 (Ct. App. 1994), and State v. David J.K, 190 Wis. 2d 726, 736 , 528 N.W.2d 434, 439 (Ct. App. 1994), is that a violation of the defendant's right to be present "does not automatically entitle [the defendant] to a new trial; such error may be found to be harmless beyond a reasonable doubt." In McMahon , the court communicated with the jury on five occasions without the defendant's presence or a waiver.

11
Leach v. Stategreen
wis · 1978 · cited in 1 Wisconsin opinions naming this issue, 1980–1980
2 sentences

1980The presence of these factors in a reinterrogation situation indicates that the potentially coercive effect of the renewed attempt to question a suspect may be held to be so low as to justify a finding that a statement elicited through questioning after the suspect has invoked his privilege is not "the product of compulsion," the primary concern of Miranda . *295 In Leach v. State, supra , we declined the defendant's invitation to limit Mosley to those situations in which a suspect invokes only the right to remain silent and instead indicated that the factors emphasized in Mosley , while not c

1980In Leach v. State, supra, we declined the defendant’s invitation to limit Mosley to those situations in which a suspect invokes only the right to remain silent and instead indicated that the factors emphasized in Mosley , while not controlling, could be considered in determining whether continued interrogation was a violation of the suspect’s right to counsel. 83 Wis.2d at 210-11, 214 .

11
United States v. Ashgreen
scotus · 1973 · cited in 1 Wisconsin opinions naming this issue, 1978–1978
2 sentences

1978However, Cox, supra, was decided prior to Ash, supra. The United States Supreme Court in Ash, supra, at 302, fn. 2, in holding that there is no right to the presence of defense counsel at a photographic identification, considered the videotape in Cox to be a photographic identification. 2 United States v. Wade, supra; Gilbert v. California, supra, sometimes referred to by this court as a Goodchild-type hearing.

1978However, Cox, supra, was decided prior to Ash, supra. The United States Supreme Court in Ash, supra, at 302, fn. 2, in holding that there is no right to the presence of defense counsel at a photographic identification, considered the videotape in Cox to be a photographic identification. 2 United States v. Wade, supra; Gilbert v. California, supra, sometimes referred to by this court as a Goodchild-type hearing.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Wisconsin. Read the followed side critically anyway.

Also cited on this issue (15)

CaseCitedYears
State v. Sabin green
wis · 1977
2 sentences

2002Sabin, 79 Wis. 2d at 306 .

2002Sabin, 79 Wis. 2d at 306 .

22002–2002
State ex rel. Fowlie v. Painter green
· 1892
2 sentences

1983This court explained the rule on adoptive admissions in Richards v. State, 82 Wis. 172, 178 , 51 N.W. 652 (1892) : “The rule is fairly to be deduced from the authorities cited to the point by the respective counsel that inculpa-tory statements, made in the presence and hearing of one accused of crime, which he, having opportunity to do so, does not deny, and the truth or falsity of which is within his personal knowledge, are admissions of the accused by acquiescence, and as such admissible in evidence. . . .” 6 Second, the adoptive admission in this case contains sufficient indicia of reliabil

1983This court explained the rule on adoptive admissions in Richards v. State, 82 Wis. 172, 178 , 51 N.W. 652 (1892): "The rule is fairly to be deduced from the authorities cited to the point by the respective counsel that inculpatory statements, made in the presence and hearing of one accused of crime, which he, having opportunity to do so, does not deny, and the truth or falsity of which is within his personal knowledge, are admissions of the accused by acquiescence, and as such admissible in evidence. . . ." [6] Second, the adoptive admission in this case contains sufficient indicia of reliabil

21923–1983
Richards v. State green
· 1892
2 sentences

1983This court explained the rule on adoptive admissions in Richards v. State, 82 Wis. 172, 178 , 51 N.W. 652 (1892) : “The rule is fairly to be deduced from the authorities cited to the point by the respective counsel that inculpa-tory statements, made in the presence and hearing of one accused of crime, which he, having opportunity to do so, does not deny, and the truth or falsity of which is within his personal knowledge, are admissions of the accused by acquiescence, and as such admissible in evidence. . . .” 6 Second, the adoptive admission in this case contains sufficient indicia of reliabil

1983This court explained the rule on adoptive admissions in Richards v. State, 82 Wis. 172, 178 , 51 N.W. 652 (1892): "The rule is fairly to be deduced from the authorities cited to the point by the respective counsel that inculpatory statements, made in the presence and hearing of one accused of crime, which he, having opportunity to do so, does not deny, and the truth or falsity of which is within his personal knowledge, are admissions of the accused by acquiescence, and as such admissible in evidence. . . ." [6] Second, the adoptive admission in this case contains sufficient indicia of reliabil

21923–1983
State v. Miller green
wis · 2012
2 sentences

2024Also like the circuit court, we ultimately conclude that the totality of the circumstances gave rise to reasonable suspicion that Johnson had operated his vehicle while intoxicated, such that Wojcik could permissibly extend the traffic stop by removing Johnson from his vehicle to perform field sobriety tests. ¶20 We consider several factors in reaching this conclusion.3 First, we note that when Wojcik made contact with Johnson, he observed that Johnson’s 3 Johnson argues that in our reasonable suspicion analysis, we may not consider the initial complaint about his driving because it was an ano

2024Also like the circuit court, we ultimately conclude that the totality of the circumstances gave rise to reasonable suspicion that Johnson had operated his vehicle while intoxicated, such that Wojcik could permissibly extend the traffic stop by removing Johnson from his vehicle to perform field sobriety tests. ¶20 We consider several factors in reaching this conclusion.3 First, we note that when Wojcik made contact with Johnson, he observed that Johnson’s 3 Johnson argues that in our reasonable suspicion analysis, we may not consider the initial complaint about his driving because it was an ano

12024–2024
United States v. Anthony Provenzano, Stephen Andretta, and Thomas Andretta green
ca3 · 1980
1 sentence

2022We emphasized, "[a]ll that the Constitution requires at such a conference is the presence of defense counsel." Id. (citing Ellis v. Oklahoma, 430 F.2d 1352, 1355 (10th Cir. 1970)) (emphasis added).

12022–2022
State v. Patrick I. Hogan green
wis · 2015
2 sentences

2021Analysis ¶18 From the legal principles summarized above, “[i]t follows that the legality of the extension of the traffic stop in this case turns on the presence of factors which, in the aggregate, amount to reasonable suspicion that [the defendant] committed a crime the investigation of which would be furthered by the defendant’s performance of field sobriety tests.” State v. Hogan, 2015 WI 76, ¶37 , 364 Wis. 2d 167 , 868 N.W.2d 124 .

2021Analysis ¶18 From the legal principles summarized above, “[i]t follows that the legality of the extension of the traffic stop in this case turns on the presence of factors which, in the aggregate, amount to reasonable suspicion that [the defendant] committed a crime the investigation of which would be furthered by the defendant’s performance of field sobriety tests.” State v. Hogan, 2015 WI 76, ¶37 , 364 Wis. 2d 167 , 868 N.W.2d 124 .

12021–2021
Amjad T. Tufail v. Midwest Hospitality, LLC green
wis · 2013
2 sentences

2018Tufail v. Midwest Hospitality, LLC , 2013 WI 62 , ¶ 30, 348 Wis. 2d 631 , 833 N.W.2d 586 .

2018Tufail v. Midwest Hospitality, LLC , 2013 WI 62 , ¶ 30, 348 Wis. 2d 631 , 833 N.W.2d 586 .

12018–2018
United States v. Morrison green
scotus · 1981
2 sentences

2006The United States Supreme Court has observed: "[W]hen a defendant is deprived of the presence and assistance of his attorney, either throughout the prosecution or during a critical stage in, at least, the prosecution of a capital offense, reversal is automatic." [47] Generally the denial of counsel is deemed a "structural error" and the harmless error analysis does not apply. [48] ¶ 75 Nonetheless, the United States Supreme Court observed in United States v. Morrison, 449 U.S. 361 , 101 S.Ct. 665 , 66 L.Ed.2d 564 (1981), that a violation of the right to counsel at certain critical stages of th

2006The United States Supreme Court has observed: "[W]hen a defendant is deprived of the presence and assistance of his attorney, either throughout the prosecution or during a critical stage in, at least, the prosecution of a capital offense, reversal is automatic." [47] Generally the denial of counsel is deemed a "structural error" and the harmless error analysis does not apply. [48] ¶ 75 Nonetheless, the United States Supreme Court observed in United States v. Morrison, 449 U.S. 361 , 101 S.Ct. 665 , 66 L.Ed.2d 564 (1981), that a violation of the right to counsel at certain critical stages of th

12006–2006
Gower v. Circuit Court for Marinette County green
wis · 1990
2 sentences

1995Court, 154 Wis. 2d 1, 12 , 452 N.W.2d 355 (1990) (citing Dewerth, 139 Wis. 2d at 552 -53 & n.4, 407 N.W.2d 862 ), we held that the actual presence requirement is satisfied when the contumacious act occurs during formal court proceedings.

1995Court, 154 Wis. 2d 1, 12 , 452 N.W.2d 355 (1990) (citing Dewerth, 139 Wis. 2d at 552 -53 & n.4, 407 N.W.2d 862 ), we held that the actual presence requirement is satisfied when the contumacious act occurs during formal court proceedings.

11995–1995
State v. Chestnut green
tenncrimapp · 1982
1 sentence

1994The trial court will always have to determine, as in Chestnut, 643 S.W.2d at 347 , the extent of testimony not heard.

11994–1994
Gilbert v. California green
scotus · 1967
1 sentence

1978However, Cox, supra, was decided prior to Ash, supra. The United States Supreme Court in Ash, supra, at 302, fn. 2, in holding that there is no right to the presence of defense counsel at a photographic identification, considered the videotape in Cox to be a photographic identification. 2 United States v. Wade, supra; Gilbert v. California, supra, sometimes referred to by this court as a Goodchild-type hearing.

11978–1978
United States v. Wade green
scotus · 1967
1 sentence

1978However, Cox, supra, was decided prior to Ash, supra. The United States Supreme Court in Ash, supra, at 302, fn. 2, in holding that there is no right to the presence of defense counsel at a photographic identification, considered the videotape in Cox to be a photographic identification. 2 United States v. Wade, supra; Gilbert v. California, supra, sometimes referred to by this court as a Goodchild-type hearing.

11978–1978
State v. Brown green
wis · 1971
1 sentence

1978State v. Brown, 60 Wis.2d 665, 673 , 185 N.W.2d 323 (1971); State ex rel.

11978–1978
Abraham v. State green
wis · 1970
2 sentences

1977Abraham v. State, 47 Wis.2d 44, 53 , 176 N.W.2d 349 (1970).

1977Abraham v. State, 47 Wis.2d 44, 53 , 176 N.W.2d 349 (1970).

11977–1977
Will of Schacht neutral
wis · 1921
2 sentences

1937Will of Schacht, 175 Wis. 54, 56 , 182 N. W. 981 .

1937Will of Schacht, 175 Wis. 54, 56 , 182 N. W. 981 .

11937–1937

Statutes the citing opinions construe

WI § Wis. Stat. § 785.03 (3) WI § Wis. Stat. § 805.13 (3) WI § Wis. Stat. § 905.05 (3) WI § Wis. Stat. § 971.04 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 168 (1889–2026) NY 126 (1858–2026) IL 120 (1899–2026) TX 110 (1909–2026) AL 86 (1845–2010) PA 83 (1896–2025) WA 56 (1901–2023) GA 56 (1900–2021) MO 52 (1867–2025) WY 47 (1936–2025) TN 41 (1948–2024) IN 38 (1872–2018) LA 36 (1915–2015) NC 32 (1881–2024) MI 32 (1911–2025) OH 31 (1881–2025) NJ 31 (1945–2026) KS 30 (1901–2026) KY 29 (1917–2025) MS 29 (1909–2022) NM 28 (1946–2022) FL 28 (1952–2026) CO 28 (1904–2024) CT 27 (1939–2025) MA 27 (1892–2026) VA 26 (1795–2023) OR 24 (1893–2025) MN 23 (1924–2018) OK 23 (1911–2015) AR 22 (1916–2024) DC 21 (1973–2019) WI 20 (1923–2024) ID 19 (1923–2022) MD 17 (1933–2014) IA 17 (1916–2023) VT 13 (1904–2026) RI 13 (1973–2014) MT 13 (1924–2024) ME 13 (1925–2019) AZ 11 (1920–2009) DE 11 (1981–2025) NE 10 (1905–2020) WV 8 (1981–2003) AK 7 (1972–2019) UT 7 (1985–2024) ND 6 (1971–2023) SD 6 (1913–2013) HI 5 (1977–2021) PR 4 (1918–1966) SC 4 (1936–2016) NH 3 (1951–1995) NV 2 (1987–2021)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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