State v. Ingram

In State v. Ingram, 204 Wis. 2d 177, 186, 554 N.W.2d 833 (Ct. App. 1996), the Court acknowledged that evidence of a defendant's parole status and violation of parole conditions is inherently prejudicial. The Court held, however, that such evidence was admissible because its prejudicial effect did not substantially outweigh its probative value. See id. at 185. Ingram was charged with fleeing an officer. See id. at 180. The evidence concerning Ingram's parole was "crucial" to the State's case because it directly explained his motive for fleeing; drinking violated his parole conditions, and Ingram did not want to be caught after he had been out drinking. See id. at 183. The Court opined, however, that "we cannot imagine too many other instances where informing the jury about the defendant's current probation or parole status, or about the defendant's success under supervision, could be more relevant than prejudicial." Id. at 190.