Wisconsin Stat. 974.06 Collateral Attacks

Challenges to a conviction filed after an unsuccessful direct appeal or after the timeline for a direct appeal has expired.

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Wisconsin Stat. 974.06 Collateral Attacks

Challenges to a conviction filed after an unsuccessful direct appeal or after the timeline for a direct appeal has expired.

Wisconsin Petitions for Sentence Modification

Motions seeking reduction or modification of criminal sentences based on new factors or changed circumstances.

Wisconsin Knight Petitions

Petitions for writ of habeas corpus in the Wisconsin Court of Appeals challenging ineffective assistance of appellate counsel in criminal cases.

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A collateral attack is a motion filed in the original criminal case challenging the conviction once the time for a direct appeal has expired or a direct appeal was unsuccessful. Unlike a direct appeal, the issues that can be raised in a collateral attack are significantly limited by statute to certain types.

These motions are limited to constitutional claims and can only be raised by an individual who is still in custody, which includes individuals on extended release, probation, or parole, as well as those still serving terms of imprisonment or jail sentences. There is no deadline to file a collateral attack.

A collateral attack following a direct appeal, or a collateral attack following a previously-filed collateral attack, cannot raise issues that were already raised in the previous proceedings. Additionally, the defendant must demonstrate "sufficient reason" why the new claims were not previously raised in the direct appeal or first collateral attack. "Sufficient reason" can include the failure of prior appellate counsel to recognize and develop a particular challenge. It is not enough that the prior attorney omitted an issue if doing so was a strategic decision, unless no reasonable appellate attorney would have omitted the issue in question.

Although there is no state-law deadline for a § 974.06 motion, defendants who may later want to seek federal habeas corpus review under 28 U.S.C. § 2254 should be aware that the federal one-year clock keeps running between state proceedings. Waiting too long to pursue state collateral relief can close the federal courthouse door even though Wisconsin law imposes no deadline of its own. And where the alleged failure lies with prior counsel on the appeal itself rather than in the trial court, the proper vehicle may instead be a Knight petition filed in the Court of Appeals.

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