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Postconviction Relief-Juror Bias

By: WISCONSIN LAW JOURNAL STAFF//December 27, 2022//

Postconviction Relief-Juror Bias

By: WISCONSIN LAW JOURNAL STAFF//December 27, 2022//

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WI Court of Appeals – District III

Case Name: State of Wisconsin v. Christopher A. Grover

Case No.: 2021AP002048-CR

Officials: Stark, P.J., Hruz and Gill, JJ.

Focus: Postconviction Relief-Juror Bias

Grover appeals conviction of fifteen criminal offenses and from an order denying his motion for postconviction relief. Grover argues that he was deprived of a fair trial because one of the jurors had a financial interest in the case and was therefore statutorily biased under WIS. STAT. § 805.08(1) (2019-20). Grover also argues that the circuit court lacked jurisdiction over the offenses charged in this case because Grover is an enrolled member of the Lac Courte Oreilles Band of Lake Superior Chippewa Indians (“the Tribe”) and the offenses took place on tribal land. The court agrees with the statement “Wisconsin’s ability to prosecute Indians for crimes committed in Indian Country is well-settled,” and Grover has provided “no reason why this Court could upend that precedent.” The court also concludes that Grover forfeited his juror bias claim, and it rejects his jurisdictional argument on the merits.

Affirmed.

Decided 12/20/22

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