Brown analysis (Wisconsin) · Go Syfert
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Brown analysis in Wisconsin

14 Wisconsin opinions name it 2 courts 1987–2023 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 (10)

CaseFollowedCited
State v. Allengreen
wis · 2004 · cited in 2 Wisconsin opinions naming this issue, 2012–2023
2 sentences

2023Id. ¶28 While “a defendant charged under a repeater statute has the right to have all evidence of any prior conviction kept from the jury trying the instant offense,” see Mulkovich v. State, 73 Wis. 2d 464, 468 , 243 N.W.2d 198 (1976), we conclude that Brown’s claim does not allege sufficient facts to demonstrate that he is entitled to relief, see Allen, 274 Wis. 2d 568, ¶9 .

2012See id.

12
State v. Camerongreen
wisctapp · 2016 · cited in 1 Wisconsin opinions naming this issue, 2023–2023
2 sentences

2023See State v. Cameron, 2016 WI App 54, ¶27 , 370 Wis. 2d 661 , 885 N.W.2d 611 (“It is not deficient performance for counsel not to make a pointless objection.”).

2023See State v. Cameron, 2016 WI App 54, ¶27 , 370 Wis. 2d 661 , 885 N.W.2d 611 (“It is not deficient performance for counsel not to make a pointless objection.”).

11
State v. Theophilous Ruffingreen
wis · 2022 · cited in 1 Wisconsin opinions naming this issue, 2023–2023
1 sentence

2023See Ruffin, 401 Wis. 2d 619, ¶35 .

11
State v. Harborgreen
wis · 2011 · cited in 1 Wisconsin opinions naming this issue, 2020–2020
2 sentences

2020See State v. Harbor, 2011 WI 28, ¶35 , 333 Wis. 2d 53 , 797 N.W.2d 828 .

2020See State v. Harbor, 2011 WI 28, ¶35 , 333 Wis. 2d 53 , 797 N.W.2d 828 .

11
State v. Bangertgreen
wis · 1986 · cited in 1 Wisconsin opinions naming this issue, 2016–2016
2 sentences

2016The State argues that the proper remedy in the instant case and others like it is reduction (commutation) of the sentence to the potential punishment the defendant was told he could receive.17 In the instant case, the State argues the 16 See Brown, 293 Wis. 2d 594, ¶6 ("If the State cannot prove by clear and convincing evidence that Brown understood the nature of the charges and the constitutional rights he gave up, the circuit court shall grant Brown's motion to withdraw his guilty pleas."); Bangert, 131 Wis. 2d at 274 ("Whenever the Section 971.08 procedure is not undertaken or whenever the

2016See Brown, 293 Wis. 2d 594, ¶ 6 ("If the State cannot prove by clear and convincing evidence that Brown understood the nature of the charges and the constitutional rights he gave up, the circuit court shall grant Brown's motion to withdraw his guilty pleas."); Bangert, 131 Wis. 2d at 274 ("Whenever the Section 971.08 procedure is not undertaken or whenever the court-mandated duties are not fulfilled at the plea hearing, the defendant may move to withdraw his plea.").

11
State v. Browngreen
wis · 2006 · cited in 1 Wisconsin opinions naming this issue, 2016–2016
2 sentences

2016The State argues that the proper remedy in the instant case and others like it is reduction (commutation) of the sentence to the potential punishment the defendant was told he could receive.17 In the instant case, the State argues the 16 See Brown, 293 Wis. 2d 594, ¶6 ("If the State cannot prove by clear and convincing evidence that Brown understood the nature of the charges and the constitutional rights he gave up, the circuit court shall grant Brown's motion to withdraw his guilty pleas."); Bangert, 131 Wis. 2d at 274 ("Whenever the Section 971.08 procedure is not undertaken or whenever the

2016See Brown, 293 Wis. 2d 594, ¶ 6 ("If the State cannot prove by clear and convincing evidence that Brown understood the nature of the charges and the constitutional rights he gave up, the circuit court shall grant Brown's motion to withdraw his guilty pleas."); Bangert, 131 Wis. 2d at 274 ("Whenever the Section 971.08 procedure is not undertaken or whenever the court-mandated duties are not fulfilled at the plea hearing, the defendant may move to withdraw his plea.").

11
State v. Andre M. Chamblisgreen
wis · 2015 · cited in 1 Wisconsin opinions naming this issue, 2016–2016
2 sentences

2016See State v. Chamblis, 2015 WI 53, ¶¶54-55 , 362 Wis. 2d 370 , 864 N.W.2d 806 . (continued) 11 No. 2014AP2488-CR circuit court correctly reduced Finley's sentence from the maximum statutory penalty, 23 years, 6 months' imprisonment,* to 19 years, 6 months' imprisonment* (even though during the plea colloquy the circuit court advised Finley that he was subject to 19 years, 6 months' confinement in prison*). ¶20 Upon consideration of Bangert, Brown, Cross, and Taylor, for the reasons set forth we conclude that under the In State v. Chamblis, the defendant was advised of the correct potential pun

2016See State v. Chamblis, 2015 WI 53, ¶¶54-55 , 362 Wis. 2d 370 , 864 N.W.2d 806 . (continued) 11 No. 2014AP2488-CR circuit court correctly reduced Finley's sentence from the maximum statutory penalty, 23 years, 6 months' imprisonment,* to 19 years, 6 months' imprisonment* (even though during the plea colloquy the circuit court advised Finley that he was subject to 19 years, 6 months' confinement in prison*). ¶20 Upon consideration of Bangert, Brown, Cross, and Taylor, for the reasons set forth we conclude that under the In State v. Chamblis, the defendant was advised of the correct potential pun

11
New York v. Harrisgreen
scotus · 1990 · cited in 1 Wisconsin opinions naming this issue, 2012–2012
2 sentences

2012See id. at 19-20 .

2012See id. at 19-20 .

11
People v. Thomasgreen
illappct · 1989 · cited in 1 Wisconsin opinions naming this issue, 1995–1995
2 sentences

1995Several jurisdictions have held confrontations may constitute intervening circumstances under the Brown analysis. " 'A defendant's confrontation with untainted evidence, which induces in the defendant a voluntary desire to confess, may be a legitimate intervening circumstance' to dissipate the taint of the defendant's earlier illegal arrest." People v. Thomas, 542 N.E.2d 881, 888 (Ill.

1995Several jurisdictions have held confrontations may constitute intervening circumstances under the Brown analysis. " 'A defendant's confrontation with untainted evidence, which induces in the defendant a voluntary desire to confess, may be a legitimate intervening circumstance' to dissipate the taint of the defendant's earlier illegal arrest." People v. Thomas, 542 N.E.2d 881, 888 (Ill.

11
People v. Whitegreen
ill · 1987 · cited in 1 Wisconsin opinions naming this issue, 1995–1995
2 sentences

1995App. 1989) (quoting People v. White, 512 N.E.2d 677, 689 (Ill. 1987)). 3 In Thomas , the defendant made incriminating statements after hearing a tape recording of his co-defendant's incriminating statement.

1995App. 1989) (quoting People v. White, 512 N.E.2d 677, 689 (Ill. 1987)). 3 In Thomas , the defendant made incriminating statements after hearing a tape recording of his co-defendant's incriminating statement.

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 (18)

CaseCitedYears
State v. Anderson green
wis · 1991
2 sentences

2012The court of appeals also noted that after Harris was decided, this court applied the Brown analysis in State v. Anderson, 165 Wis. 2d 441 , 477 N.W.2d 277 (1991), and State v. Phillips, 218 Wis. 2d 180 , 577 N.W.2d 794 (1998), involving the suppression of evidence obtained following a warrantless home entry and search.

2012The court of appeals also noted that after Harris was decided, this court applied the Brown analysis in State v. Anderson, 165 Wis. 2d 441 , 477 N.W.2d 277 (1991), and State v. Phillips, 218 Wis. 2d 180 , 577 N.W.2d 794 (1998), involving the suppression of evidence obtained following a warrantless home entry and search.

22010–2012
Mulkovich v. State green
wis · 1976
2 sentences

2023Id. ¶28 While “a defendant charged under a repeater statute has the right to have all evidence of any prior conviction kept from the jury trying the instant offense,” see Mulkovich v. State, 73 Wis. 2d 464, 468 , 243 N.W.2d 198 (1976), we conclude that Brown’s claim does not allege sufficient facts to demonstrate that he is entitled to relief, see Allen, 274 Wis. 2d 568, ¶9 .

2023Id. ¶28 While “a defendant charged under a repeater statute has the right to have all evidence of any prior conviction kept from the jury trying the instant offense,” see Mulkovich v. State, 73 Wis. 2d 464, 468 , 243 N.W.2d 198 (1976), we conclude that Brown’s claim does not allege sufficient facts to demonstrate that he is entitled to relief, see Allen, 274 Wis. 2d 568, ¶9 .

12023–2023
State v. George E. Savage green
wis · 2020
1 sentence

2022Id. ¶20 On appeal, Brown raises the same three ineffective assistance of counsel claims that he raised before the circuit court: (1) Brown’s trial counsel misinformed Brown regarding his SAP eligibility; (2) counsel failed to advise Brown that Count 3 was ineligible for SAP; and (3) counsel failed to inform 9 No. 2021AP878-CR Brown that he could have withdrawn his pleas prior to being sentenced.9 For the reasons that follow, we affirm the court’s conclusion that Brown’s trial counsel was not constitutionally ineffective. ¶21 Brown first alleges that he was “affirmatively misled when trial coun

12022–2022
State v. Minerva Lopez green
wis · 2014
2 sentences

2022State v. Lopez, 2014 WI 11, ¶61 , 353 Wis. 2d 1 , 843 N.W.2d 390 (citation omitted).

2022State v. Lopez, 2014 WI 11, ¶61 , 353 Wis. 2d 1 , 843 N.W.2d 390 (citation omitted).

12022–2022
State v. Sigarroa green
wisctapp · 2003
2 sentences

2020Accordingly, we review only the circuit court’s decision denying Brown’s motion for a mistrial. ¶8 “The decision whether to grant a mistrial lies within the sound discretion of the [circuit] court.” State v. Sigarroa, 2004 WI App 16, ¶24 , 269 Wis. 2d 234 , 674 N.W.2d 894 (2003).

2020Accordingly, we review only the circuit court’s decision denying Brown’s motion for a mistrial. ¶8 “The decision whether to grant a mistrial lies within the sound discretion of the [circuit] court.” State v. Sigarroa, 2004 WI App 16, ¶24 , 269 Wis. 2d 234 , 674 N.W.2d 894 (2003).

12020–2020
State v. Mainiero green
wisctapp · 1994
2 sentences

2018However, the prior consistent statement " 'must predate the alleged recent fabrication or improper influence or motive before [it has] probative value.' " State v. Mainiero , 189 Wis. 2d 80 , 103, 525 N.W.2d 304 (Ct. App. 1994) (citation omitted).

2018However, the prior consistent statement " 'must predate the alleged recent fabrication or improper influence or motive before [it has] probative value.' " State v. Mainiero , 189 Wis. 2d 80 , 103, 525 N.W.2d 304 (Ct. App. 1994) (citation omitted).

12018–2018
State v. Brown neutral
wisctapp · 2013
2 sentences

2014It concluded that "[a] tail lamp with one of three light bulbs unlit does not violate Wis. Stat. § 347.13 (1) when it otherwise meets the statutory definition of a tail lamp." State v. Brown, 2013 WI App 17, ¶21 , 346 Wis. 2d 98 , 827 N.W.2d 903 .

2014It concluded that "[a] tail lamp with one of three light bulbs unlit does not violate Wis. Stat. § 347.13 (1) when it otherwise meets the statutory definition of a tail lamp." State v. Brown, 2013 WI App 17, ¶21 , 346 Wis. 2d 98 , 827 N.W.2d 903 .

12014–2014
State v. Cross green
wis · 2010
2 sentences

2014The court of appeals relied on State v. Cross, 2010 WI 70 , 326 Wis. 2d 492 , 786 N.W.2d 64 (wherein the circuit court gave Cross mistaken information about the crime to which he pled); State v. Woods, 173 Wis. 2d 129 , 496 N.W.2d 144 (Ct. App. 1992) (wherein the court erred by imposing a sentence to run consecutive to a juvenile disposition that Woods was then serving); State v. Brown, 2004 WI App 179 , 276 Wis. 2d 559 , 687 N.W.2d 543 (wherein the court erred by stating that Brown's plea did not trigger sex offender registration or Wis. Stat. ch. 980 commitment potential).

2014The court of appeals relied on State v. Cross, 2010 WI 70 , 326 Wis. 2d 492 , 786 N.W.2d 64 (wherein the circuit court gave Cross mistaken information about the crime to which he pled); State v. Woods, 173 Wis. 2d 129 , 496 N.W.2d 144 (Ct. App. 1992) (wherein the court erred by imposing a sentence to run consecutive to a juvenile disposition that Woods was then serving); State v. Brown, 2004 WI App 179 , 276 Wis. 2d 559 , 687 N.W.2d 543 (wherein the court erred by stating that Brown's plea did not trigger sex offender registration or Wis. Stat. ch. 980 commitment potential).

12014–2014
State v. Brown green
wisctapp · 2004
2 sentences

2014The court of appeals relied on State v. Cross, 2010 WI 70 , 326 Wis. 2d 492 , 786 N.W.2d 64 (wherein the circuit court gave Cross mistaken information about the crime to which he pled); State v. Woods, 173 Wis. 2d 129 , 496 N.W.2d 144 (Ct. App. 1992) (wherein the court erred by imposing a sentence to run consecutive to a juvenile disposition that Woods was then serving); State v. Brown, 2004 WI App 179 , 276 Wis. 2d 559 , 687 N.W.2d 543 (wherein the court erred by stating that Brown's plea did not trigger sex offender registration or Wis. Stat. ch. 980 commitment potential).

2014The court of appeals relied on State v. Cross, 2010 WI 70 , 326 Wis. 2d 492 , 786 N.W.2d 64 (wherein the circuit court gave Cross mistaken information about the crime to which he pled); State v. Woods, 173 Wis. 2d 129 , 496 N.W.2d 144 (Ct. App. 1992) (wherein the court erred by imposing a sentence to run consecutive to a juvenile disposition that Woods was then serving); State v. Brown, 2004 WI App 179 , 276 Wis. 2d 559 , 687 N.W.2d 543 (wherein the court erred by stating that Brown's plea did not trigger sex offender registration or Wis. Stat. ch. 980 commitment potential).

12014–2014
State v. Woods green
wisctapp · 1992
2 sentences

2014The court of appeals relied on State v. Cross, 2010 WI 70 , 326 Wis. 2d 492 , 786 N.W.2d 64 (wherein the circuit court gave Cross mistaken information about the crime to which he pled); State v. Woods, 173 Wis. 2d 129 , 496 N.W.2d 144 (Ct. App. 1992) (wherein the court erred by imposing a sentence to run consecutive to a juvenile disposition that Woods was then serving); State v. Brown, 2004 WI App 179 , 276 Wis. 2d 559 , 687 N.W.2d 543 (wherein the court erred by stating that Brown's plea did not trigger sex offender registration or Wis. Stat. ch. 980 commitment potential).

2014The court of appeals relied on State v. Cross, 2010 WI 70 , 326 Wis. 2d 492 , 786 N.W.2d 64 (wherein the circuit court gave Cross mistaken information about the crime to which he pled); State v. Woods, 173 Wis. 2d 129 , 496 N.W.2d 144 (Ct. App. 1992) (wherein the court erred by imposing a sentence to run consecutive to a juvenile disposition that Woods was then serving); State v. Brown, 2004 WI App 179 , 276 Wis. 2d 559 , 687 N.W.2d 543 (wherein the court erred by stating that Brown's plea did not trigger sex offender registration or Wis. Stat. ch. 980 commitment potential).

12014–2014
Laasch v. State green
wis · 1978
2 sentences

2012According to Felix, applying a Brown analysis in this case is consistent with this court's decisions in Laasch, 84 Wis. 2d 587 , Smith, 131 Wis. 2d 220 , and Walker, 154 Wis. 2d 158 , which predate Harris.

2012According to Felix, applying a Brown analysis in this case is consistent with this court's decisions in Laasch, 84 Wis. 2d 587 , Smith, 131 Wis. 2d 220 , and Walker, 154 Wis. 2d 158 , which predate Harris.

12012–2012
Edwards v. Arizona green
scotus · 1981
2 sentences

2012Additionally, as the Supreme Court noted in Harris , evidence will still be suppressed if it was "the product of coercion, if Miranda warnings were not given, or if there was a violation of the rule of Edwards v. Arizona, 451 U.S. 477 (1981)." Id. at 20.

2012Additionally, as the Supreme Court noted in Harris , evidence will still be suppressed if it was "the product of coercion, if Miranda warnings were not given, or if there was a violation of the rule of Edwards v. Arizona, 451 U.S. 477 (1981)." Id. at 20.

12012–2012
State v. Eason green
wis · 2001
2 sentences

2012Felix asserts that this court should conclude, as it did in Eason, 245 Wis. 2d 206 , that this is a situation in which the United States Supreme Court's interpretation of the Fourth Amendment does not protect a defendant's Article I, Section 11 rights.

2012Felix asserts that this court should conclude, as it did in Eason, 245 Wis. 2d 206 , that this is a situation in which the United States Supreme Court's interpretation of the Fourth Amendment does not protect a defendant's Article I, Section 11 rights.

12012–2012
State v. Smith green
wis · 1986
2 sentences

2012According to Felix, applying a Brown analysis in this case is consistent with this court's decisions in Laasch, 84 Wis. 2d 587 , Smith, 131 Wis. 2d 220 , and Walker, 154 Wis. 2d 158 , which predate Harris.

2012According to Felix, applying a Brown analysis in this case is consistent with this court's decisions in Laasch, 84 Wis. 2d 587 , Smith, 131 Wis. 2d 220 , and Walker, 154 Wis. 2d 158 , which predate Harris.

12012–2012
State v. Walker green
wis · 1990
2 sentences

2012According to Felix, applying a Brown analysis in this case is consistent with this court's decisions in Laasch, 84 Wis. 2d 587 , Smith, 131 Wis. 2d 220 , and Walker, 154 Wis. 2d 158 , which predate Harris.

2012According to Felix, applying a Brown analysis in this case is consistent with this court's decisions in Laasch, 84 Wis. 2d 587 , Smith, 131 Wis. 2d 220 , and Walker, 154 Wis. 2d 158 , which predate Harris.

12012–2012
State v. Phillips green
wis · 1998
2 sentences

2012The court of appeals also noted that after Harris was decided, this court applied the Brown analysis in State v. Anderson, 165 Wis. 2d 441 , 477 N.W.2d 277 (1991), and State v. Phillips, 218 Wis. 2d 180 , 577 N.W.2d 794 (1998), involving the suppression of evidence obtained following a warrantless home entry and search.

2012The court of appeals also noted that after Harris was decided, this court applied the Brown analysis in State v. Anderson, 165 Wis. 2d 441 , 477 N.W.2d 277 (1991), and State v. Phillips, 218 Wis. 2d 180 , 577 N.W.2d 794 (1998), involving the suppression of evidence obtained following a warrantless home entry and search.

12012–2012
Brown v. Illinois green
scotus · 1975
2 sentences

2010Id. at 603-04 , 95 S.Ct. 2254 . ¶ 67 Although Brown specifically addressed a confession made after an illegal arrest, this court has applied the Brown factors to the context of an illegal search.

2010Id. at 603-04 , 95 S.Ct. 2254 . ¶ 67 Although Brown specifically addressed a confession made after an illegal arrest, this court has applied the Brown factors to the context of an illegal search.

12010–2010
Brown v. Hammermill Paper Co. green
wis · 1979
2 sentences

1987Id. at 232-33 , 276 N.W.2d at 712-13 .

1987Id. at 232-33 , 276 N.W.2d at 712-13 .

11987–1987

Statutes the citing opinions construe

WI § Wis. Stat. § 808.10 (5) WI § Wis. Stat. § 971.08 (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

TX 122 (1901–2026) CA 102 (1967–2026) FL 65 (1975–2023) GA 62 (1975–2026) PA 58 (1974–2026) OH 56 (1974–2026) MS 47 (1985–2026) OR 45 (1971–2025) IL 40 (1968–2026) WA 31 (1936–2025) IN 31 (1979–2021) NY 28 (1848–2026) MI 28 (1988–2023) KS 28 (1991–2026) MO 27 (1912–2022) NE 23 (1983–2024) AL 23 (1918–2024) LA 22 (1952–2023) CO 21 (1980–2026) AZ 21 (2004–2026) TN 20 (1960–2026) MD 20 (1960–2021) DC 19 (1981–2025) IA 19 (1976–2024) MN 18 (1974–2025) ID 17 (1987–2026) VA 16 (1990–2022) WI 14 (1987–2023) DE 13 (1970–2025) SC 13 (1990–2026) UT 12 (1941–2025) NJ 12 (1990–2018) NC 10 (1961–2026) WY 10 (1987–2021) ME 9 (1979–2016) NV 9 (1990–2017) CT 9 (1982–2026) MA 8 (1982–2007) AK 8 (1984–2023) MT 8 (1996–2022) NM 6 (1986–2020) AR 6 (1976–2022) KY 6 (1984–2026) RI 6 (1976–2011) SD 6 (1992–2019) OK 6 (1935–2021) ND 4 (1991–2009) HI 4 (2009–2025) WV 3 (1979–1996) VT 2 (2008–2018) VI 2 (2008–2011)

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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