State v. Kourtidias

In State v. Kourtidias, 206 Wis. 2d 573, 557 N.W.2d 858 (Ct. App. 1996), the Court rejected the State's attempt to use evidence that a defendant was on parole and violating his parole conditions to show that the defendant had an irresistible impulse to commit the type of crime with which he was charged. (See id. at 586.) The Court announced the law governing admission of a defendant's parole status: "Evidence of a defendant's probation or parole status and relevant conditions thereof are admissible in the proper exercise of judicial discretion if such evidence demonstrates the motive for, or otherwise explains, the defendant's alleged criminal conduct. Absent that scenario, such evidence is inadmissible because the nexus between the conduct and the potential penalty is too tenuous." (Id. at 585.)