State v. Krier
In State v. Krier, 165 Wis. 2d 673, 478 N.W.2d 63 (Ct. App. 1991), the court reviewed whether an officer needs reasonable suspicion or probable cause to pull over a car driven by someone suspected of driving without a license.
Driving without a license can be a civil or criminal matter depending on whether the driver has prior offenses.
The court held that "when a person's activity can constitute either a civil forfeiture or a crime, a police officer may validly perform an investigative stop ...." Id. at 678.
The court also discussed the application of Wis. Stat. 968.24 and concluded that the statute applied "because the police had an articulable and reasonable suspicion that he was engaged in an activity that could be criminal. That verb is all that is required here." Id.