Sara J. Geenen

Authored the majority. Four older criminal-procedure decisions had drifted in different directions; Geenen pulled them into a workable rule. She acknowledged the broader concern about defendants being penalized for going to trial, but kept her holding inside the dispute the parties briefed rather than expanding it into a structural critique of the system.

Four older court decisions on the same criminal-procedure question had pointed in different directions over the years. That left judges and lawyers guessing at what the rule actually was. Geenen's job was to clean up the confusion. She did. She wrote a clear rule that ties the older cases together, and she did it without using the case to tackle bigger arguments the parties had not raised. That is how an appeals court is supposed to work: settle the question in front of you and stop there.

Authored the majority. A juvenile defendant in adult criminal court asked for discovery before a probable-cause hearing that determines whether the case stays in adult court. The Wisconsin Supreme Court had said in Kleser that juveniles get "some latitude," but never specified what that meant. Geenen filled the gap carefully: juveniles get the State's introduced evidence as a matter of right, plus other materials only on a particularized showing of need. Faithful precedent-following without overreach.

The case involved a young person's right to certain information about their case. There was already a Wisconsin Supreme Court rule that covered the question. Geenen's job was to figure out how that rule applied to these facts. She did, cleanly. She didn't try to write a new rule or push the law into new territory. She just applied the rule the higher court had already set. That is solid, careful work.