State v. Carrizales
In State v. Carrizales, 191 Wis. 2d 85, 528 N.W.2d 29 (Ct. App. 1995), the Court held that the Fifth Amendment does not give a probationer the right to refuse to admit guilt for the crime he or she was convicted of during a treatment program that was a condition of the probation. See id. at 94.
The Court reasoned that admitting guilt during the course of a treatment program, following a conviction for sexual assault, did not create a risk that the probationer's admission would result in incrimination in a separate criminal proceeding. See id. at 95.