Statutory Interpretation – Coercion

By: Derek Hawkins//August 19, 2021//

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WI Court of Appeals – District II

Case Name: State of Wisconsin v. Chrystul D. Kizer

Case No.: 2020AP192-CR

Officials: Reilly, P.J., Gundrum and Davis, JJ.

Focus: Statutory Interpretation – Coercion – Affirmative Defense

Charged with numerous felonies, including first-degree intentional homicide, Chrystul D. Kizer sought interlocutory appeal from an order of the circuit court that effectively prevents her from introducing evidence of the affirmative defense of WIS. STAT. § 939.46(1m), related to victims of human trafficking and child sex trafficking. We granted leave to appeal the order, and because we conclude the circuit court erred in its interpretation of § 939.46(1m), we reverse.

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