accident defense (Wisconsin) · Go Syfert
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accident defense in Wisconsin

9 Wisconsin opinions name it 2 courts 1923–2025 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 (7)

CaseFollowedCited
State v. Bondgreen
wis · 1969 · cited in 3 Wisconsin opinions naming this issue, 2001–2025
2 sentences

2025“The accident defense prevails in a homicide case only in situations in which ‘a person unfortunately kills another in doing a lawful act without any intent to kill and without criminal negligence.’” State v. Watkins, 2002 WI 101, ¶43 , 255 Wis. 2d 265 , 647 N.W.2d 244 (quoting State v. Bond, 41 Wis. 2d 219, 228 , 163 N.W.2d 601 (1969) (discussing homicide by misadventure)).

2025“The accident defense prevails in a homicide case only in situations in which ‘a person unfortunately kills another in doing a lawful act without any intent to kill and without criminal negligence.’” State v. Watkins, 2002 WI 101, ¶43 , 255 Wis. 2d 265 , 647 N.W.2d 244 (quoting State v. Bond, 41 Wis. 2d 219, 228 , 163 N.W.2d 601 (1969) (discussing homicide by misadventure)).

13
State v. Watkinsgreen
wis · 2002 · cited in 2 Wisconsin opinions naming this issue, 2021–2025
2 sentences

2025“The accident defense prevails in a homicide case only in situations in which ‘a person unfortunately kills another in doing a lawful act without any intent to kill and without criminal negligence.’” State v. Watkins, 2002 WI 101, ¶43 , 255 Wis. 2d 265 , 647 N.W.2d 244 (quoting State v. Bond, 41 Wis. 2d 219, 228 , 163 N.W.2d 601 (1969) (discussing homicide by misadventure)).

2025“The accident defense prevails in a homicide case only in situations in which ‘a person unfortunately kills another in doing a lawful act without any intent to kill and without criminal negligence.’” State v. Watkins, 2002 WI 101, ¶43 , 255 Wis. 2d 265 , 647 N.W.2d 244 (quoting State v. Bond, 41 Wis. 2d 219, 228 , 163 N.W.2d 601 (1969) (discussing homicide by misadventure)).

12
State v. Gomazgreen
wis · 1987 · cited in 1 Wisconsin opinions naming this issue, 2024–2024
2 sentences

2024See State v. Gomaz, 141 Wis. 2d 302, 313-14 , 414 N.W.2d 626 (1987).

2024See State v. Gomaz, 141 Wis. 2d 302, 313-14 , 414 N.W.2d 626 (1987).

11
Commonwealth v. Turnergreen
massappct · 1987 · cited in 1 Wisconsin opinions naming this issue, 2002–2002
1 sentence

2002In Gunn v. State, 365 N.E.2d 1234, 1239 (Ind. Ct. App. 1977), the court stated that "[BJecause the proper exercise of the right to defend oneself is a lawful act, such an act may satisfy the requirement that the accused be engaged in a lawful act when a killing occurs accidentally." In Commonwealth v. Turner, 506 N.E.2d 151, 153 (Mass. App. Ct. 1987), the court stated, "[T]he principles of self-defense may be involved in an accident defense, not for purposes of establishing the defense of self-defense but to show that the defendant was engaged in a lawful act." Similarly, an "accused is entitl

11
Gunn v. Stategreen
indctapp · 1977 · cited in 1 Wisconsin opinions naming this issue, 2002–2002
1 sentence

2002In Gunn v. State, 365 N.E.2d 1234, 1239 (Ind. Ct. App. 1977), the court stated that "[BJecause the proper exercise of the right to defend oneself is a lawful act, such an act may satisfy the requirement that the accused be engaged in a lawful act when a killing occurs accidentally." In Commonwealth v. Turner, 506 N.E.2d 151, 153 (Mass. App. Ct. 1987), the court stated, "[T]he principles of self-defense may be involved in an accident defense, not for purposes of establishing the defense of self-defense but to show that the defendant was engaged in a lawful act." Similarly, an "accused is entitl

11
State v. Headgreen
wis · 2002 · cited in 1 Wisconsin opinions naming this issue, 2002–2002
2 sentences

2002See State v. Head, 2002 WI 99 , 255 Wis. 2d 194 , 648 N.W.2d 413 , and State v. Camacho, 176 Wis. 2d 860, 865, 872 , 501 N.W.2d 380 (1993) for a discussion of the objective reasonable threshold necessary to assert perfect self-defense. *293 C.

2002See State v. Head, 2002 WI 99 , 255 Wis. 2d 194 , 648 N.W.2d 413 , and State v. Camacho, 176 Wis. 2d 860, 865, 872 , 501 N.W.2d 380 (1993) for a discussion of the objective reasonable threshold necessary to assert perfect self-defense. *293 C.

11
State v. Camachogreen
wis · 1993 · cited in 1 Wisconsin opinions naming this issue, 2002–2002
2 sentences

2002See State v. Head, 2002 WI 99 , 255 Wis. 2d 194 , 648 N.W.2d 413 , and State v. Camacho, 176 Wis. 2d 860, 865, 872 , 501 N.W.2d 380 (1993) for a discussion of the objective reasonable threshold necessary to assert perfect self-defense. *293 C.

2002See State v. Head, 2002 WI 99 , 255 Wis. 2d 194 , 648 N.W.2d 413 , and State v. Camacho, 176 Wis. 2d 860, 865, 872 , 501 N.W.2d 380 (1993) for a discussion of the objective reasonable threshold necessary to assert perfect self-defense. *293 C.

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 (8)

CaseCitedYears
State v. Dundon green
wis · 1999
2 sentences

2021Having concluded that Ruffin was not entitled to the accident instruction, “[w]e would be hard pressed to conclude that [trial] counsel performed deficiently in failing to request a jury instruction to an invalid defense.” State v. Dundon, 226 Wis. 2d 654, 676 , 594 N.W.2d 780 (1999).

2021Having concluded that Ruffin was not entitled to the accident instruction, “[w]e would be hard pressed to conclude that [trial] counsel performed deficiently in failing to request a jury instruction to an invalid defense.” State v. Dundon, 226 Wis. 2d 654, 676 , 594 N.W.2d 780 (1999).

12021–2021
State v. Allen green
wis · 2004
2 sentences

2021Lastly, he argues that his trial counsel was ineffective for withdrawing the request for the self-defense jury instruction for the sexual assault charge. ¶16 “A hearing on a postconviction motion is required only when the movant states sufficient material facts that, if true, would entitle the defendant to relief.” State v. Allen, 2004 WI 106, ¶14 , 274 Wis. 2d 568 , 682 N.W.2d 433 . 6 We pause to note that Ruffin has requested relief in the form of a vacated conviction.

2021Lastly, he argues that his trial counsel was ineffective for withdrawing the request for the self-defense jury instruction for the sexual assault charge. ¶16 “A hearing on a postconviction motion is required only when the movant states sufficient material facts that, if true, would entitle the defendant to relief.” State v. Allen, 2004 WI 106, ¶14 , 274 Wis. 2d 568 , 682 N.W.2d 433 . 6 We pause to note that Ruffin has requested relief in the form of a vacated conviction.

12021–2021
State v. Mayhall green
wisctapp · 1995
1 sentence

2021Therefore, we conclude that the denial was a reasonable exercise of discretion and trial counsel was not ineffective. ¶34 “As long as jury instructions fully and fairly inform the jury of the law applicable to the particular case, the trial court has discretion in deciding which instructions will be given.” State v. Mayhall, 195 Wis. 2d 53, 57 , 535 15 No. 2019AP1046-CR N.W.2d 473 (Ct. App. 1995).

12021–2021
State v. Langlois green
wisctapp · 2017
1 sentence

2018Id. , ¶35.

12018–2018
State v. Gonzalez neutral
wisctapp · 2010
1 sentence

2011The court of appeals ruled that because the defendant's defense of accidental exhibiting "was adequately covered by the other instructions given to the jury, he was not entitled to an accident instruction." Gonzalez, 328 Wis. 2d 182, ¶ 17 .

12011–2011
State v. Ferguson green
wis · 2009
2 sentences

2011State v. Ferguson, 2009 WI 50, ¶ 9 , 317 Wis. 2d 586 , 767 N.W.2d 187 .

2011State v. Ferguson, 2009 WI 50, ¶ 9 , 317 Wis. 2d 586 , 767 N.W.2d 187 .

12011–2011
State v. Ambuehl green
wisctapp · 1988
1 sentence

2006Id. *172 Similarly, Attorney Berk's failure to request an instruction on accident was not deficient performance.

12006–2006
Hildebrand v. Carroll green
wis · 1900
2 sentences

1923This position is not in conflict with the declarations of this court upon the question. ' The cases relied upon by appellant (Hildebrand v. Carroll, 106 Wis. 324 , 82 N. W. 145 ; Lipsky v. C.

1923This position is not in conflict with the declarations of this court upon the question. ' The cases relied upon by appellant (Hildebrand v. Carroll, 106 Wis. 324 , 82 N. W. 145 ; Lipsky v. C.

11923–1923

Statutes the citing opinions construe

WI § Wis. Stat. § 752.35 (3) WI § Wis. Stat. § 808.10 (3) WI § Wis. Stat. § 939.23 (3) WI § Wis. Stat. § 939.48 (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 92 (1919–2026) NY 76 (1901–2026) GA 71 (1962–2026) LA 59 (1907–2026) OH 52 (1929–2026) PA 45 (1932–2023) MI 43 (1903–2026) MA 32 (1927–2026) MO 27 (1883–2019) IL 24 (1927–2026) MS 24 (1932–2026) IN 15 (1950–2023) VA 14 (1929–2025) MN 14 (1971–2024) MD 13 (1939–2015) FL 13 (1932–2021) NJ 13 (1912–2006) TX 12 (1972–2019) NC 12 (1936–2021) SC 11 (1971–2025) AZ 10 (1967–2024) WI 9 (1923–2025) CT 7 (1973–2012) KY 7 (1952–1977) WY 6 (1970–2017) NH 6 (1973–1999) ME 6 (1977–2013) UT 5 (1938–1994) NE 5 (1945–1982) KS 5 (1926–2018) NM 5 (1944–2025) ID 5 (1957–2015) AL 5 (1985–2017) RI 5 (1983–2016) WV 4 (1961–2022) DC 4 (1962–1990) SD 4 (1938–2026) OR 4 (1972–2021) WA 4 (2000–2026) MT 3 (1978–2003) IA 3 (1924–1947) CO 3 (1909–2005) AK 3 (1971–1988) TN 2 (1975–2004) DE 2 (1989–2008) ND 2 (1995–2009)

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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