Wisconsin

Berghuis v. Thompkins in Wisconsin Law

How Berghuis v. Thompkins applies in Wisconsin: state-specific rules, key cases, and bar exam notes for Criminal Procedure.

State Approach

Wisconsin adheres to the principles established in Berghuis v. Thompkins, emphasizing that a suspect must unambiguously invoke their right to remain silent to trigger protections under Miranda. The state courts often stress the necessity for a clear and affirmative expression of the desire to cease questioning.

State Rule
Under Wisconsin law, a suspect’s invocation of their right to silence must be clear and unambiguous, and law enforcement is not required to stop questioning until the suspect expressly demonstrates the desire to do so.
Significant State Cases

State v. Stietz

The court held that equivocal statements made during interrogation do not suffice to invoke the right to silence.

State v. Lonkoski

The Wisconsin Supreme Court reaffirmed that the right to remain silent is not activated unless the suspect clearly expresses their intention to invoke it.

State v. Smith

The court ruled that a suspect's silence in response to questions does not constitute an invocation of the right to remain silent.

Comparison to Federal Law

Wisconsin's application of the principles from Berghuis v. Thompkins aligns closely with the federal standard, which also requires an unambiguous invocation of the right to remain silent. However, Wisconsin jurisprudence may emphasize the necessity for clarity more stringently than some federal interpretations.

Bar Exam Note

Questions regarding the invocation of Miranda rights and the clarity needed to invoke the right to remain silent are often tested in the Wisconsin bar exam.

Practice Pointers
  • Always advise clients to speak clearly and unequivocally if they wish to invoke their right to silence during police interrogations.
  • Be familiar with both state and federal standards regarding interrogations to effectively argue the adequacy of a client's invocation of rights.
  • Keep updated on evolving case law concerning the interpretation of Miranda rights in Wisconsin, as court decisions may shift the standards.

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