State v. Marcos Banuelos

CourtCourt of Appeals of Wisconsin
DecidedMarch 19, 2026
Docket2025AP000830
StatusUnpublished

This text of State v. Marcos Banuelos (State v. Marcos Banuelos) is published on Counsel Stack Legal Research, covering Court of Appeals of Wisconsin primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Marcos Banuelos, (Wis. Ct. App. 2026).

Opinion

COURT OF APPEALS DECISION NOTICE DATED AND FILED This opinion is subject to further editing. If published, the official version will appear in the bound volume of the Official Reports. March 19, 2026 A party may file with the Supreme Court a Samuel A. Christensen petition to review an adverse decision by the Clerk of Court of Appeals Court of Appeals. See WIS. STAT. § 808.10 and RULE 809.62.

Appeal No. 2025AP830 Cir. Ct. No. 2016CF1512

STATE OF WISCONSIN IN COURT OF APPEALS DISTRICT IV

STATE OF WISCONSIN,

PLAINTIFF-RESPONDENT,

V.

MARCOS BANUELOS,

DEFENDANT-APPELLANT.

APPEAL from an order of the circuit court for Dane County: NICHOLAS J. MCNAMARA, Judge. Affirmed.

Before Graham, P.J., Blanchard, and Kloppenburg, JJ.

Per curiam opinions may not be cited in any court of this state as precedent

or authority, except for the limited purposes specified in WIS. STAT. RULE 809.23(3). No. 2025AP830

¶1 PER CURIAM. Marcos Banuelos, pro se, appeals a circuit court order denying his postconviction motion, brought under WIS. STAT. § 974.06 (2023-24), to withdraw his plea based on newly discovered evidence.1 We reject Banuelos’s arguments and affirm.

BACKGROUND

¶2 Banuelos was charged with one count of misdemeanor disorderly conduct. He was also charged with six felony counts of sexual assault-related conduct that, taken together, involved multiple children. In the lead-up to Banuelos’s trial, the State moved to admit various pieces of “other acts” evidence related to Banuelos’s alleged history of sexual contact with children.

¶3 While represented by retained counsel, Banuelos pled guilty to one count of second-degree sexual assault of “A.B.,” a child under 16 years of age.2 Pursuant to a negotiated plea agreement, the remaining counts were dismissed and read in for sentencing. As part of the plea agreement, the State also agreed to cap its sentencing recommendation for initial confinement at five years. The court sentenced Banuelos to ten years of initial confinement and 15 years of extended supervision.

¶4 Banuelos, by counsel, filed a postconviction motion seeking to withdraw his guilty plea, alleging that his trial counsel provided ineffective assistance of counsel. The circuit court denied the motion, and Banuelos

1 All references to the Wisconsin Statutes are to the 2023-24 version. 2 To protect the dignity and privacy of the victim, we refer to her as A.B., using initials that do not correspond to her real name. See WIS. STAT. RULES 809.19(1)(g) and 809.86.

2 No. 2025AP830

appealed. This court affirmed the circuit court’s judgment and order in a per curiam decision. See State v. Banuelos, No. 2022AP741, unpublished slip op. (WI App Nov. 30, 2023).

¶5 In December 2024, Banuelos, representing himself, filed the WIS. STAT. § 974.06 postconviction motion that is the subject of this appeal. In his motion, Banuelos argued, among other things, that he is entitled to an evidentiary hearing and to withdrawal his guilty plea on the basis of newly discovered evidence.

¶6 We pause here to briefly describe the newly discovered evidence offered by Banuelos. Banuelos asserts that, after his conviction, he discovered a news article entitled “Four New Complaints Outlined Against DeForest Police Chief” (hereafter “the article”). The article described certain allegations that were made against the police chief of the DeForest Police Department (DFPD). According to the article, the police chief was alleged to have engaged in various types of misconduct, including the following: (1) he was heard in a video making comments about a group of African-American men; (2) he allowed inappropriate content to be posted on his own and the DFPD’s social media pages; (3) he failed to investigate an employee despite multiple complaints about conduct that could be considered sexual harassment; and (4) he publicly distributed a confidential video portraying a graphic domestic violence event. In his motion to the court, Banuelos argued that the article exposed evidence that the DFPD police chief “condoned, ratified, and encouraged rampant malfeasance throughout the department.”

¶7 Banuelos’s argument to the circuit court in support of his WIS. STAT. § 974.06 motion can most favorably be construed as follows. Banuelos argued

3 No. 2025AP830

that he is entitled to withdraw his plea because DFPD was the department that investigated the charges against Banuelos, and the misconduct exposed in the article gives Banuelos reason to believe that the officers handling his case were engaged in unchecked misconduct. Additionally, he argued that the State committed a Brady violation by failing to disclose evidence in its possession regarding the alleged misconduct exposed in the article. See Brady v. Maryland, 373 U.S. 83 (1963). Under these circumstances, Banuelos argued, he is entitled to a postconviction hearing to prove that, had the State disclosed information that a DFPD employee was not investigated by the police chief despite multiple complaints about sexual harassment, Banuelos could have used the information to attack the credibility of the officers involved in handling Banuelos’s case.

¶8 In a written decision and order, the circuit court denied Banuelos’s motion without an evidentiary hearing. The court concluded that Banuelos did not show by clear and convincing evidence that withdrawal of his guilty plea is necessary to correct a manifest injustice. In denying Banuelos’s request for an evidentiary hearing on the motion, the court determined that Banuelos’s allegations were conclusory and that Banuelos did not allege sufficient material facts that, if true, would entitle him to withdraw his plea.

DISCUSSION

¶9 Any claim that could have been raised in a prior postconviction motion or on direct appeal cannot form the basis for a claim under WIS. STAT. § 974.06 unless the defendant demonstrates a sufficient reason for failing to raise the claim in the prior postconviction motion or appeal. State v. Escalona- Naranjo, 185 Wis. 2d 168, 185, 517 N.W.2d 157 (1994). Banuelos asserts that the fact that his motion is based on newly discovered evidence constitutes a

4 No. 2025AP830

sufficient reason for failing to raise his current claims in his prior motion and appeal.

¶10 On appeal, Banuelos argues that the circuit court erred in concluding that Banuelos did not establish that his purported newly discovered evidence constitutes a manifest injustice. He also asserts that the court erred in denying his request for a hearing to prove that the State violated its Brady obligations.

¶11 A defendant seeking to withdraw a plea on the basis of newly discovered evidence must make a clear and convincing showing that the newly discovered evidence establishes that a manifest injustice has occurred. State v. Krieger, 163 Wis. 2d 241, 255, 471 N.W.2d 599 (Ct. App. 1991). To prevail on such a claim, the defendant must show by clear and convincing evidence that: “(1) the evidence was discovered after conviction; (2) the defendant was not negligent in seeking evidence; (3) the evidence is material to an issue in the case; and (4) the evidence is not merely cumulative.” State v. McAlister, 2018 WI 34, ¶31, 380 Wis. 2d 684, 911 N.W.2d 77. If the defendant establishes these four criteria, the circuit court must then “determine whether a reasonable probability exists that a different result would be reached in a trial.”3 Id., ¶32 (citation omitted).

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Related

Brady v. Maryland
373 U.S. 83 (Supreme Court, 1963)
State v. Rockette
2006 WI App 103 (Court of Appeals of Wisconsin, 2006)
State v. Escalona-Naranjo
517 N.W.2d 157 (Wisconsin Supreme Court, 1994)
State v. Allen
2004 WI 106 (Wisconsin Supreme Court, 2004)
State v. Krieger
471 N.W.2d 599 (Court of Appeals of Wisconsin, 1991)
State v. David McAlister, Sr.
2018 WI 34 (Wisconsin Supreme Court, 2018)
State v. Theophilous Ruffin
2022 WI 34 (Wisconsin Supreme Court, 2022)

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Bluebook (online)
State v. Marcos Banuelos, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-marcos-banuelos-wisctapp-2026.