State v. Bollig (1999)
In State v. Bollig, 224 Wis. 2d 621, 593 N.W.2d 67 (Ct. App. 1999), the Court asserted that, "the requirement that a convicted sex offender register with the appropriate agency appears, at least initially, to be a direct consequence of pleading no contest," to the underlying offense. Id. at 636.
The Court then attempted to determine whether the registration requirement constitutes a punishment. See id. We first considered a similar requirement for juvenile offenders in Wisconsin, which the state supreme court determined did not constitute punishment, and then we considered other states' registration requirements.
The Court concluded that the registration requirement is not a direct punishment, but rather it is "a safeguard to protect past victims and the public in general." Id. at 639.
The Court elected to adopt the majority conclusion and held "that a trial court is not required to notify a defendant of this registration requirement in order for the plea to be valid." Id. at 638-39.