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Postconviction Motion – Admissible Evidence

WI Court of Appeals – District I

Case Name: State of Wisconsin v. Andrew Lorenzo Wren

Case No.: 2021AP790-CR

Officials: Brash, C.J., Donald, P.J., and White, J.

Focus: Postconviction Motion – Admissible Evidence

Wren appeals from his conviction for possession with intent to deliver cocaine and possession with intent to deliver narcotics, both with the use of a dangerous weapon and both as a second or subsequent offense, and for possession of a firearm by a felon. He also appeals from the order denying his postconviction motion.

Wren argues that the trial court erred in denying his motion to suppress the evidence that was discovered in his vehicle, on the grounds that the police officers did not have reasonable suspicion for the stop; the trial court, in contrast, deemed it to be a field interview as opposed to a seizure, thus determining that reasonable suspicion was not required. Wren further argues that the trial court erred in denying his motion to suppress his statements to law enforcement during that encounter. Upon review, we conclude that while the facts of this case do not necessarily support the trial court’s finding that this was a field interview, there was nevertheless reasonable suspicion for the police officers to stop Wren. We further conclude that the questions posed to Wren during this stop did not invoke the protections of Miranda v. Arizona, 384 U.S. 436 (1966). Therefore, the trial court did not err in denying Wren’s motions to suppress.


Decided 09/27/22

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