Sufficiency of Evidence

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WI Court of Appeals – District I

Case Name: State of Wisconsin v. Steven Tyrone Bratchett

Case No.: 2020AP1347-CR

Officials: Donald, P.J., Dugan and White, JJ.

Focus: Sufficiency of Evidence

Steven Tyrone Bratchett appeals his judgment of conviction for burglary, armed robbery, and attempted third-degree sexual assault, with various penalty enhancers and as a party to a crime. He also appeals the order denying his motion for postconviction relief. Bratchett argues that the trial court erred when it concluded that the photo array by which the alleged victim identified him was sufficiently reliable and when it admitted a photo of Bratchett wearing prison orange, which he argued was unfairly prejudicial. He further argues that trial counsel was ineffective for failing to impeach the alleged victim with a prior statement, for failing to cross-examine the alleged victim about the photo identification procedures, for failing to object to the prosecutor’s hypothetical statements in closing arguments, and for cumulative deficiencies. Finally, he asserts that the evidence was insufficient to convict him on the attempted third-degree sexual assault charge. We reject all of his arguments, and accordingly, we affirm.

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Derek A Hawkins is Corporate Counsel, at Salesforce.