State v. Steven L. Harris

CourtCourt of Appeals of Wisconsin
DecidedJuly 7, 2026
Docket2024AP002227-CR
StatusUnpublished

This text of State v. Steven L. Harris (State v. Steven L. Harris) 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. Steven L. Harris, (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. July 7, 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. 2024AP2227-CR Cir. Ct. No. 2020CF1476

STATE OF WISCONSIN IN COURT OF APPEALS DISTRICT I

STATE OF WISCONSIN,

PLAINTIFF-RESPONDENT,

V.

STEVEN L. HARRIS,

DEFENDANT-APPELLANT.

APPEAL from an order of the circuit court for Milwaukee County: KATIE B. KEGEL, Judge. Affirmed.

Before Donald, C.J., Colón, P.J., and Geenen, J.

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. 2024AP2227-CR

¶1 PER CURIAM. Steven L. Harris appeals from the circuit court’s nonfinal order denying Harris’s motion to dismiss.1 Harris argues that the circuit court incorrectly determined that there was a manifest necessity for declaring a mistrial in Harris’s first criminal trial, and absent a manifest necessity, Harris’s double jeopardy rights prohibit the State from retrying him for the same offenses.

¶2 For the following reasons, we conclude that the circuit court did not erroneously exercise its discretion by declaring a mistrial based on manifest

1 While we acknowledge that our supreme court has declined to direct that we grant appeals from denied motions to dismiss based on double jeopardy as a matter of course, State v. Jenich, 94 Wis. 2d 74, 97A n.1, 292 N.W.2d 348 (1980), our view is that substantial and irreparable harm will always follow from subjecting a defendant to an unlawful second trial, see State v. Jendusa, 2021 WI 24, ¶20 n.12, 396 Wis. 2d 34, 955 N.W.2d 777 (characterizing this harm as a “compelling reason[]” to exercise its superintending power, though recognizing that it had chosen not to do so in Jenich). The defendant’s petition for leave to appeal does not stay the enforcement of the order appealed from, and the trial court may proceed with the second trial while the appeal is pending. WIS. STAT. § 808.07; see also Jenich, 94 Wis. 2d 74, 97H (Abrahamson, J., concurring on motion for reconsideration). Thus, we think these appeals will always meet the criteria set forth in WIS. STAT. § 808.03(2) governing permissive appeals.

On this issue, we agree with Justice Abrahamson’s concurrence on the motion for reconsideration in Jenich:

I conclude that in order to grant effective protection to the defendant’s rights under the double jeopardy provisions of the state and federal constitutions and in order to provide effective administration of the criminal justice system in the state, [the Wisconsin Supreme Court] should, as did the United States Supreme Court in [Abney v. United States, 431 U.S. 651 (1977)], require immediate appellate review in the court of appeals of a pretrial order rejecting a claim of double jeopardy. If the court of appeals can determine from the petitioner’s and state’s papers on the petition for leave to appeal that the claim is frivolous, the court of appeals should grant leave to appeal and decide the appeal on the merits immediately by a summary affirmance.... I would further require the court of appeals to establish procedures pursuant to [WIS. STAT.] RULE 809.20 … for expediting appeals involving double jeopardy claims.

Jenich, 94 Wis. 2d 74, 97G (Abrahamson, J., concurring on motion for reconsideration).

2 No. 2024AP2227-CR

necessity. Thus, the mistrial does not prevent the State from retrying Harris for the same offenses. Accordingly, we affirm the circuit court’s order.2

BACKGROUND

¶3 In April 2020, the State charged Harris with eleven crimes related to ongoing cocaine dealing and possession of several guns as a felon. Harris’s trial commenced in November 2023. A thirteen-member jury was empaneled and sworn, and opening instructions and statements were concluded the first day. Before trial commenced the next morning, a person with no connection to the case attacked one juror in the bathroom, shoving the juror into a stall, and demanding money. A second juror was also approached by this person, and the person tried to take the second juror’s watch. The person was combative with the court deputies and was arrested and criminally charged. The jurors were all directed to the jury room while the person was arrested. Harris witnessed the person being arrested as he was being brought into the courthouse, and Harris’s attorney spoke with him about what happened.

¶4 The circuit court commented that the juror involved in the bathroom incident “was very, very shaken,” and it “would not, under any circumstances, make a juror sit through a trial after having experienced something like that.” The circuit court observed that two jurors had been accosted, “[i]t’s a longer trial,” and it had concerns about the rest of the panel being “poison[ed]” given that, once the jurors were all placed together in the jury room, “everybody kind of had an idea of

2 We instructed the parties to brief the merits of Harris’s double jeopardy argument, and we now resolve the case against Harris on the merits. Thus, we grant Harris’s petition for leave to appeal, and we affirm the circuit court’s order.

3 No. 2024AP2227-CR

what had happened.” The court therefore declared a mistrial, discharged the jury, and scheduled a new trial in January 2024. Harris requested that his counsel move to modify his bail, and after argument from the parties, the court denied the motion because it determined that Harris was still a risk to community safety.

¶5 In July 2024, Harris filed a pro se motion3 to dismiss on double jeopardy grounds, arguing that there was no manifest necessity for the November 2023 mistrial. The circuit court denied the motion. The court recounted what happened with the jurors on the morning that the mistrial was declared and explained, “I would never have allowed a trial to continue for someone to come in and sit here and listen to that. I don’t think that would have been fair to Mr. Harris.” It continued,

I wouldn’t want someone to paint with a broad brush and think that person did something criminal to me, so all criminals are bad, all people charged with crimes [are] bad, all of those things. That would bias that juror just because of their own personal experience and the recency in which it had happened. There was no real way to know what the other jurors know, what they were told. Obviously, they were all in the same room as this juror was physically shaken, upset, very clearly impacted by this, and she and the [other] juror who had been attacked presumably would have compared notes somewhat of what did she say to you, what did she say to you, whatever. All of that occurred.

3 While we do not have all of the details on the proceedings that took place between the mistrial and the rescheduled trial date, this court may take judicial notice of electronic circuit court docket entries. See Kirk v. Credit Acceptance Corp., 2013 WI App 32, ¶5 n.1, 346 Wis. 2d 635, 829 N.W.2d 522. It appears, based on CCAP records, that Harris’s counsel moved to withdraw in January 2024. The case was adjourned and successor counsel was appointed. Harris then requested to proceed pro se, with appointed counsel as stand-by counsel, which the court allowed after conducting a colloquy with Harris.

4 No. 2024AP2227-CR

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Related

Abney v. United States
431 U.S. 651 (Supreme Court, 1977)
State v. Blalock
442 N.W.2d 514 (Court of Appeals of Wisconsin, 1989)
State v. Kelty
2006 WI 101 (Wisconsin Supreme Court, 2006)
State v. Seefeldt
2003 WI 47 (Wisconsin Supreme Court, 2003)
State v. Lettice
585 N.W.2d 171 (Court of Appeals of Wisconsin, 1998)
State v. Mink
429 N.W.2d 99 (Court of Appeals of Wisconsin, 1988)
State v. Copening
303 N.W.2d 821 (Wisconsin Supreme Court, 1981)
State v. Jenich
288 N.W.2d 114 (Wisconsin Supreme Court, 1980)
State v. Anthony James Jendusa
2021 WI 24 (Wisconsin Supreme Court, 2021)
Kirk v. Credit Acceptance Corp.
2013 WI App 32 (Court of Appeals of Wisconsin, 2013)
State v. Mitchell D. Green
2023 WI 57 (Wisconsin Supreme Court, 2023)

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Bluebook (online)
State v. Steven L. Harris, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-steven-l-harris-wisctapp-2026.