Shirley Abrahamson
Shirley Abrahamson
Prior offices
Wisconsin Supreme Court
Education
Shirley S. Abrahamson was a justice on the Wisconsin Supreme Court. She was initially appointed to the bench by Democratic Governor Patrick Lucey in 1976 and was subsequently elected to 10-year terms in 1979, 1989, 1999, and 2009. She did not seek re-election in 2019, effectively leaving the office on July 31, 2019.[1] She served as chief justice of the court from August 1996 to April 2015.
Being the senior-most member of the court on August 1, 1996, Abrahamson became chief justice. In 2015, Wisconsin voters approved a constitutional amendment requiring that the chief justice be elected to that position by a majority vote of the court's members. Justice Patience Roggensack was elected to succeed Justice Abrahamson as chief justice on April 29, 2015.[2] Abrahamson filed an unsuccessful federal lawsuit in April attempting to block the implementation of the amendment.
Abrahamson was the first woman to serve on the Wisconsin Supreme Court and the first woman to serve as its chief justice.[3] On April 10, 2013, after 36 years, seven months and four days on the court, Abrahamson became the longest-serving member of the court, breaking the previous record held by Orsamus Cole, who served from 1855 to 1892.[2]
Abrahamson died on December 19, 2020, at the age of 87.[4]
Education
Abrahamson received her B.A. from New York University in 1953 and her J.D. from Indiana University Maurer School of Law in 1956. In 1962, she earned her doctorate of law in American legal history from the University of Wisconsin Law School.[5]
Career
After graduating from law school, Abrahamson went into private practice for 14 years. During this time, she was also a professor at the University of Wisconsin Law School. Abrahamson was appointed to the Wisconsin Supreme Court in 1976 and served as chief justice from 1996 to 2015.[3]
Awards and associations
Awards
- 2010: John Marshall Award, American Bar Association[6]
- 2009: Harry L. Carrico Award for Judicial Innovation, National Center for State Courts
- 2004: Dwight D. Opperman Award for Judicial Excellence, American Judicature Society
- Honorary Doctor of Laws degrees, 15 universities
- Distinguished Alumni Award, University of Wisconsin-Madison
Associations
- Fellow, Wisconsin Academy of Arts and Sciences
- Fellow, American Academy of Arts and Sciences
- Elected member, American Philosophical Society
- Member, Council of the American Law Institute
- Member, New York University School of Law Institute of Judicial Administration
- Past president, National Conference of Chief Justices
- Past chair, Board of Directors, National Center for State Courts[7]
- Past chair, National Institute of Justice's National Commission on the Future of DNA Evidence
- Past member, State Bar of Wisconsin's Commission on the Delivery of Legal Services
- Past member, Coalition for Justice, American Bar Association
- Past member, Science, Technology and Law panel, National Academy[3]
Elections
2019
- See also: Wisconsin Supreme Court elections, 2019
Shirley Abrahamson did not file to run for re-election.
2009
Abrahamson was re-elected to her fourth term on the Wisconsin Supreme Court on April 7, 2009. With that election's victory, Abrahamson became the longest serving justice in the 162-year history of the Wisconsin Supreme Court. It also made her only the second justice in Wisconsin history to ever win election to the court four times.[8]
For a list of Abrahamson's campaign contributions, visit the Wisconsin Democracy Campaign.
| Candidate | Incumbent | Election % |
|
|---|---|---|---|
Shirley Abrahamson  |
Yes | 59.6% | |
| Randy Koschnick | No | 40.2% |
Abrahamson's contributions questioned
On February 12, 2009, the Associated Press reported that Justice Abrahamson had received more than $30,000 since August 2008 from attorneys with cases pending before the Wisconsin Supreme Court. In one medical malpractice case, three attorneys representing the plaintiffs donated $11,500 to the Abrahamson campaign.[10]
Abrahamson explained her position on the matter, stating that it was better to accept small donations from a variety of donors than large amounts from a few organizations or individuals. Furthermore, she said that any lawyer who questioned the donations could have filed a motion to have her step aside in a case, though none did.[10]
Approach to the law
Abrahamson is an advocate of judicial independence. Her essay, "Judicial Independence as a Campaign Platform," articulates the debate as follows:
| “ | Many judicial candidates are choosing not to exercise their First Amendment rights fully because they are concerned they may tarnish the public's perception of fairness and impartiality, and may disqualify themselves from sitting on cases. ... In any judicial selection system, the best way to ensure judicial independence is to develop the public's understanding of, and respect for, the concept of judicial independence. ... Judicial independence means that judges decide cases fairly and impartially, relying only on the facts and the law. ... There are two types of judicial independence: decisional independence and institutional independence (sometimes called branch independence). Decisional independence refers to a judge's ability to render decisions free from political or popular influence; decisions should be based solely upon the facts of the individual case and the applicable law. Institutional independence describes the judicial branch as a separate and co-equal branch of government with the executive and legislative branches.[11] | ” |
| —Shirley Abrahamson[12] |
Political affiliation
Only nine states hold partisan elections for their appellate courts. Other states hold nonpartisan elections or use a combination of appointments and retention elections.
Nonpartisan elections in some states require judges to declare their partisan affiliations; in other states, judges are not required to declare a political affiliation and in fact may be prohibited from doing so.
Ballotpedia collects information about the political and ideological leanings of judges to offer better context for court decisions.
Wisconsin Supreme Court justices are selected in nonpartisan judicial elections by the voters of Wisconsin. In the case of a vacancy, the governor can appoint a new justice, but that justice must stand for election in the next year in which no other justice will be up for election.
Elections
Abrahamson was appointed to the Wisconsin Supreme Court in 1979 by Democratic Governor Patrick Lucey. She has never run in a partisan election.
Political contributions
According to publicly available campaign finance records, Abrahamson limited her donations to nonpartisan candidates also running for the Wisconsin Supreme Court.[13]
| Year | Race | Candidate | Contribution | Won/Lost |
|---|---|---|---|---|
| 1990 | Wisconsin Supreme Court | Richard Brown | $210 | Lost |
| 1994 | Wisconsin Supreme Court | Janine P. Geske | $700 | Won |
| 1995 | Wisconsin Supreme Court | Ted Wedemeyer Jr | $750 | Lost |
| 1996 | Wisconsin Supreme Court | N. Patrick Crooks | $95 | Won |
| 1996 | Wisconsin Supreme Court | Stanley Miller | $100 | Lost |
| 1996 | Wisconsin Supreme Court | Charles Schudson | $50 | Lost |
| 1996 | Wisconsin Supreme Court | Ted Wedemeyer Jr | $200 | Lost |
| 1996 | Wisconsin Supreme Court | Harold Froehlich | $25 | Lost |
| 1997 | Wisconsin Supreme Court | Walt Kelly | $100 | Lost |
| 1997 | Wisconsin Supreme Court | Jon Wilcox | $250 | Won |
| 1999 | Wisconsin Supreme Court | Shirley Abrahamson (self) | $116,458 | Won |
| 2009 | Wisconsin Supreme Court | Shirley Abrahamson (self) | $52,084 | Won |
Political donors
The following table includes the five organizations that donated the most to Abrahamson's campaigns to the Wisconsin Supreme Court, according to publicly available campaign finance information.[14]
| Donor | Contribution |
|---|---|
| Wisconsin Education Association Council | $20,650 |
| Wisconsin State AFL-CIO | $10,000 |
| Wisconsin Communication Workers | $8,625 |
| Wisconsin State Auto Workers | $5,000 |
| Northwest United Educators | $5,000 |
Endorsements and scorecards
In her most recent re-election campaign in 2009, 70 police chiefs across the state of Wisconsin endorsed Abrahamson.[15]
Political ideology
In October 2012, political science professors Adam Bonica and Michael Woodruff of Stanford University attempted to determine the partisan ideology of state supreme court justices. They created a scoring system in which a score above 0 indicated a more conservative-leaning ideology, while scores below 0 were more liberal.
Abrahamson received a campaign finance score of -1.29, indicating a liberal ideological leaning. This was more liberal than the average score of 0.42 that justices received in Wisconsin.
The study was based on data from campaign contributions by the judges themselves, the partisan leaning of those who contributed to the judges' campaigns, or, in the absence of elections, the ideology of the appointing body (governor or legislature). This study was not a definitive label of a justice, but an academic summary of various relevant factors.[16]
New Federalism
Abrahamson advocated expanded civil liberties in the states via "New Federalism," arguing that state supreme courts should feel free to interpret state constitutional provisions differently than the U.S. Supreme Court interprets the federal constitution, especially regarding the rights of criminal defendants. In an article published by the journal, Human Rights, she defined it this way:
| “ | In judicial jargon, new federalism describes a growing awareness in the state courts of the importance of state law, especially state constitutional law, as the basis for protection of individual rights against state government. It also describes the willingness of state courts to assert themselves as the final arbiters in questions of citizens’ individual rights by relying on their own state law, especially the state constitution.[11] | ” |
According to the now-defunct website, GOP3.com, expanded federalism was a way to protect judges in the state courts who practiced judicial activism in hopes that the Supreme Court of the United States or a federal court of appeals would not overturn their rulings.[17]
Impact of chief justice amendment
The Wisconsin Supreme Court Chief Justice Amendment, also known as Question 1, was on the April 7, 2015, ballot in Wisconsin as a legislatively referred constitutional amendment, where it was approved. The measure provided for the election of the Wisconsin Supreme Court Chief Justice by a majority of the justices serving on the court. The amendment allowed the chief justice chosen by the court to serve a two-year term.[18] Election officials certified the results of the April 7 vote on April 29, 2015.[19]
Before Question 1's passage, the Wisconsin Constitution mandated that the chief justice be appointed based on seniority from the pool of seven justices sitting on the Wisconsin Supreme Court. At the time, Abrahamson had served as the court's chief justice since 1996. She was considered a liberal, but the court majority was considered conservative, according to the Milwaukee Journal Sentinel.[20]
Opponents argued that the amendment was a political attack on Abrahamson and that the seniority method was more democratic because it allowed the justice who had been elected by voters the most times to be chief justice, while supporters contended the majority-vote system was more democratic because the justices would decide who would be the head of the court, thereby decreasing conflict among the justices.[21]
Justices vote to remove Abrahamson as chief
On the same day that state election officials certified the amendment, the justices of the supreme court held a vote by email. The conservatives, who made up a majority of the court, selected Patience Roggensack to replace Abrahamson as the new chief justice.[19]
Justice Ann Walsh Bradley expressed disappointment with the vote, saying that it was not a settled question whether the constitutional amendment was retroactive in application. Justice Michael Gableman, a Roggensack supporter, responded to Bradley's argument:
| “ | Part of the judge's written decision when he denied Chief Justice Abrahamson's request for a temporary restraining order to block the members of the court from voting for a new chief justice reads: 'When and how to implement a duly passed amendment to the Wisconsin Constitution is a question of state law, not federal law.'[11] | ” |
| —Justice Michael Gableman[19] |
Federal Judge James Peterson, who is hearing Abrahamson's case, said he desired for a vote to be put on hold until he ruled, but he had also twice declined Abrahamson's request to block the vote. Voting for chief justice was technically open until Friday, May 1, 2015, but it was doubtful any justice would change their mind or their vote.[19]
Federal lawsuit by Abrahamson
Abrahamson, along with five registered voters, filed a federal lawsuit on April 8, 2015, unsuccessfully seeking to block implementation of an approved amendment to the state constitution that changed how the chief justice was selected. Federal judge James D. Peterson, on July 31, 2015, ruled in favor of the defendant's request for a dismissal. Peterson concluded that there was no compelling reason for federal courts to intervene on a state amendment interpreted by voters.
Timeline:
- Question 1, approved on April 7, changed chief justice selection from a seniority system to a process where justices choose a chief for a two-year term. The lawsuit, filed with the U.S. District Court for Western Wisconsin, argued that Abrahamson's rights to due process and equal protection were abridged by the amendment. Her filing sought to block application of the amendment until her term expired in 2019 or she left office prior to that year. Abrahamson filed the suit against the six members of the court, Secretary of State Doug La Follette (D), and State Treasurer Matt Adamczyk (R).[22][23]
The filed complaint stated:
| “ | Should the new method of selecting a chief justice be put into immediate effect before the expiration of Chief Justice Abrahamson’s current term and a new chief justice selected, the term of the current, elected chief justice will be disrupted, her constitutionally protected interest in the office of chief justice will be impaired, the votes of her supporters will be diluted and the results of the 2009 election undone long after-the-fact, while the Wisconsin court system’s leadership will become unsettled. The retroactive application of the new amendment raises profound issues of Due Process and Equal Protection under the Fourteenth Amendment to the Constitution of the United States.[11] | ” |
| —Shirley Abrahamson et al. v. Department of Administration[24] |
The five registered state voter plaintiffs all listed the following as their complaint:
| “ | The challenged amendment if construed as applicable to Chief Justice Abrahamson and given retroactive effect dilutes the value of his vote and upsets his settled expectations by limiting the term of the candidate he successfully supported in the 2009 election.[11] | ” |
| —Shirley Abrahamson et al. v. Department of Administration[24] |
- Abrahamson, who served as chief justice from 1996 until fellow justices voted for her replacement on April 29, also sought a restraining order against her fellow justices, which would have prevented a vote to remove her as chief. Judge James Peterson rejected the request for a temporary restraining order on April 9, opting to wait until a hearing on April 21 to evaluate Abrahamson's filing in light of testimony from defendants.[25][26] Abrahamson and other plaintiffs did not contact the defendants about the restraining order application prior to the filing, which is a requirement of Federal Rules of Civil Procedure (FRCP) Rule 65.[27]
Supreme Court Justice Ann Walsh Bradley decided to defend herself in the lawsuit, breaking with her five colleagues. The other five justices were defended by former Deputy Attorney General Kevin St. John, who was paid $300 an hour by the state, although his contract was capped at $100,000.[28]
- On April 21, Judge Peterson declined to block the amendment from going into effect while the lawsuit was pending. He claimed there would be no "irreparable harm" if Abrahamson was temporarily removed from her position. However, he warned the other justices not to replace her too quickly, saying, "The state would be well-served to have as few changes in chief justice as possible."[29] On May 15, the judge refused to fulfill a request from Abrahamson to stop the court from electing a new chief justice. Peterson contended that recently elected Chief Justice Patience Roggensack had not proposed any radical changes to the court's structure; thus, there would be no harm in allowing Roggensack to be chief justice while the case moved forward.[30]
- On July 31, 2015, Judge Peterson ruled in favor of the defendant's request for a dismissal. Peterson concluded that there was no compelling reason for federal courts to intervene on a state amendment interpreted by voters. In his ruling, Peterson stated:
| “ |
Constitutional provisions are drawn with broad strokes ... There is no requirement that a state, in restructuring its government or the powers and duties of its officials by means of a constitutional amendment, do so with super-clarity to protect the interests of the officials or voters whose interests might be impaired. Unless its actions are plainly unconstitutional, Wisconsin has the authority and autonomy to restructure its government without interference from the federal government. [11] |
” |
| —Milwaukee Journal Sentinel, (2015), [31] |
Responses
Brandon Scholz, an organizer of the pro-amendment group Vote Yes for Democracy, made the following statement in response to the lawsuit:
| “ |
I find it surprising that someone who has served as long as Justice Abrahamson has, for what would appear to be self-serving reasons, files the lawsuit in federal court against the will of the people.[23][11] |
” |
Both the Milwaukee Journal Sentinel and Beloit Daily News called on Abrahamson to drop the lawsuit.[32][33] The Capital Times editorial board, on the other hand, backed Abrahamson's lawsuit.[34]
On April 14, 2015, members of Citizens for Responsible Government, a political action committee, asked the court to allow it to intervene in the case. The group argued against the validity of Abrahamson's lawsuit and sought to have the case thrown out. David Rivkin, an attorney for those asking to intervene, contended, "The office of chief justice of the Supreme Court of Wisconsin is not Justice Abrahamson's personal property. It belongs to the people of Wisconsin, and their will is clear."[35]
Noteworthy events
Justice and representative discuss potential legislation limiting judicial service (2015)
On March 22, 2015, Abrahamson testified before the Wisconsin Legislature's Joint Finance Committee about the judiciary budget for the 2015 fiscal year. Representative Dean Knudson, a member of that committee, said he wanted to submit a bill to the legislature mandating a retirement age for all judges in the state.
Potential legislation—in conjunction with the constitutional amendment restructuring how the supreme court chief justice was selected, which voters approved on April 7, 2015—was reportedly seen as an attempt by conservative members of the legislature to oust Abrahamson—or at the very least, to curtail her influence and power on the court.[36]
Knudson pointed out that a 1977 amendment to the Wisconsin Constitution said that the legislature "shall" set a mandatory retirement age for judges in the state. He said it was a constitutional obligation. Abrahamson replied that the legislature had yet to do so. Knudson further indicated that well over half of the states had mandatory judicial retirement ages.[36] A transcript of the exchange between Abrahamson and Knudson can be found here.
Thirty-three states have mandatory retirement ages; of those, 10 have considered doing away with the mandate.
Articles:
Abrahamson dissents on cases concerning the use of cell phone tracking
- See also: Wisconsin Supreme Court (State v. Subdiaz-Osorio, State v. Tate)
- See also: Wisconsin Supreme Court (State v. Subdiaz-Osorio, State v. Tate)
In July 2014, the Wisconsin Supreme Court ruled on two similar cases regarding the constitutionality of using cell phones to track individuals. In both cases, police tracked the cell phones of suspected murderers.
In the case of Nicolas Subdiaz-Osorio, who killed his brother and then attempted to flee to Mexico, police tracked him down in Arkansas with the help of the cell phone provider Sprint Nextel without obtaining a warrant. The Kenosha County Circuit Court denied Subdiaz-Orsorio's motion to suppress evidence, after which he pleaded guilty to first-degree reckless homicide. An appeals court upheld the conviction, and on July 24, the supreme court did as well. Chief Justice Shirley Abrahamson was the only justice to dissent with the majority ruling. She noted that citizens have a right to privacy, and that the "State failed to demonstrate that any of the three purported circumstances advanced by Justice Prosser’s lead opinion – threat to safety, risk of destruction of evidence, and increased likelihood of flight – existed with sufficient urgency to justify the privacy violation in the instant case."[37]
In the second case, police used cell phone data to track down Bobby Tate, who was a murder suspect. Police obtained a warrant and quickly located him. A circuit court denied his motion to suppress evidence, which he filed on claims that there was not sufficient probable cause for the warrant, and that the warrant did not establish a specific location to be searched. Again an appeals court upheld the conviction of the circuit court. A 5-2 majority of the state supreme court agreed with the lower courts. Abrahamson again dissented, this time joined by Justice Ann Walsh Bradley. Abrahamson said the majority opinion avoided the core issue of whether the government's use of cell phone location data is a "search." She stated, "Rather than dance around the issue … I propose that the court address it head-on."[38]
John Doe investigations
Two John Doe investigations, beginning in 2010 and ending in 2015, were launched by Milwaukee County District Attorney John Chisholm (D) into the activities of staff and associates of Gov. Scott Walker (R).[39] The Wisconsin Supreme Court officially put an end to the investigations in a 4-2 ruling on July 16, 2015, noting that "a state law outlawing such coordination was 'unconstitutionally overbroad and vague under the First Amendment'" and that "the special prosecutor's legal theory is unsupported in either reason or law."[40][41] Abrahamson and N. Patrick Crooks wrote separate dissenting opinions in the case. Abrahamson's opinion concluded:
| “ |
Lest the length, convoluted analysis, and overblown rhetoric of the majority opinion obscure its effect, let me state clearly: The majority opinion adopts an unprecedented and faulty interpretation of Wisconsin's campaign finance law and of the First Amendment. In doing so, the majority opinion delivers a significant blow to Wisconsin's campaign finance law and to its paramount objectives of 'stimulating vigorous campaigns on a fair and equal basis' and providing for 'a better informed electorate.' [11] |
” |
| —Shirley Abrahamson[41] |
Recent news
The link below is to the most recent stories in a Google news search for the terms Shirley Abrahamson Wisconsin Supreme Court. These results are automatically generated from Google. Ballotpedia does not curate or endorse these articles.
See also
External links
- Project Vote Smart, "Chief Justice Shirley S. Abrahamson (WI)"
- Wisconsin Court System, "Justice Abrahamson's 2011 State of the Judiciary Address"
Footnotes
- ↑ Wisconsin Public Radio, "Longtime Wisconsin Justice Shirley Abrahamson Won't Seek Re-Election," May 30, 2018
- ↑ 2.0 2.1 Wisconsin Court System, "Chief Justice Abrahamson becomes longest-serving justice in Wisconsin history," April 11, 2013
- ↑ 3.0 3.1 3.2 Wisconsin Court System, "Chief Justice Shirley S. Abrahamson"
- ↑ Milwaukee Journal Sentinel, "Shirley Abrahamson, longest-serving member of Wisconsin Supreme Court, dies at 87," December 20, 2020
- ↑ Project Vote Smart, "Chief Justice Shirley S. Abrahamson (WI)"
- ↑ Wisconsin Court System, "Chief Justice Abrahamson honored with 2010 John Marshall Award," August 12, 2010
- ↑ National Center for State Courts, "Wisconsin’s Chief Justice Named Chair-Elect of National Court Reform Organization," October 15, 2003
- ↑ NBC 15, "UPDATE: Influential Wisconsin Justice Wins Re-election," April 7, 2009
- ↑ Wisconsin Government Accountability Board, "Results of Spring General Election," April 7, 2009
- ↑ 10.0 10.1 The Milwaukee Journal-Sentinel, "Abrahamson won't return donations from lawyers," February 24, 2009
- ↑ 11.0 11.1 11.2 11.3 11.4 11.5 11.6 11.7 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
- ↑ Washington State Bar Association, "Judicial Independence as a Campaign Platform," March 5, 2005
- ↑ Follow the Money, "Shirley Abrahamson" accessed June 28, 2016
- ↑ Follow the Money, "Shirley S Abrahamson," accessed July 8, 2016
- ↑ WKOW, "Police chiefs across state endorse Abrahamson for Supreme Court," accessed June 28, 2016
- ↑ Stanford University, "State Supreme Court Ideology and 'New Style' Judicial Campaigns," October 31, 2012
- ↑ 17.0 17.1 EBSCO, "Reincarnation & reawakening," accessed January 20, 2016
- ↑ Wisconsin Legislature, "2013 Senate Joint Resolution 57," accessed May 8, 2014
- ↑ 19.0 19.1 19.2 19.3 Journal Sentinel, "State high court quickly ousts Shirley Abrahamson as chief justice," April 29, 2015
- ↑ Milwaukee Journal Sentinel, "Constitutional amendment would let court select chief justice," October 29, 2013
- ↑ Hudson Star-Observer, "Supreme Court governance issue inches toward April ballot; state's housing market nearly recovered; 12 more Wisconsin stories," January 20, 2015
- ↑ Milwaukee Journal-Sentinel, "Abrahamson sues to keep her job for four more years," April 8, 2015
- ↑ 23.0 23.1 Wisconsin State Journal, "Chief Justice Shirley Abrahamson sues over amendment approved by voters," April 8, 2015
- ↑ 24.0 24.1 United States District Court for the Western District of Wisconsin, "Shirley Abrahamson et al. v. Department of Administration," April 8, 2015
- ↑ Milwaukee Journal-Sentinel, "Judge declines to immediately halt chief justice amendment," April 9, 2015
- ↑ UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WISCONSIN, "Case: 3:15-cv-00211-jdp," April 9, 2015
- ↑ Election Law Blog, "Federal Court to WI Chief Justice Abrahamson: Follow Federal Rules for TROs," April 10, 2015
- ↑ Connecticut Post, "Justice Bradley to defend herself in Abrahamson lawsuit," April 21, 2015
- ↑ Wisconsin State Journal, "Judge declines to block chief justice selection change," April 21, 2015
- ↑ Wisconsin Public Radio, "Judge Says He Won't Block Supreme Court Chief Justice Amendment," May 15, 2015
- ↑ Milwaukee Journal Sentinel, "Judge dismisses Shirley Abrahamson suit to regain chief justice role," July 31, 2015
- ↑ Milwaukee Journal Sentinel, "Wisconsin Chief Justice Shirley Abrahamson should drop her lawsuit," April 14, 2015
- ↑ Beloit Daily News, "Accept the will of state’s voters," April 13, 2015
- ↑ The Capital Times, "Chief Justice Abrahamson is right to seek clarification of conflict," April 15, 2015
- ↑ Milwaukee Journal Sentinel, "Conservative group seeks to intervene in chief justice case," April 13, 2015
- ↑ 36.0 36.1 Milwaukee Wisconsin Journal Sentinel, "Shirley Abrahamson could be forced out of Supreme Court chief justice role," December 22, 2014
- ↑ Wisconsin State Bar Association, "Deeply Divided Court Rules in Warrantless Cell Phone Tracking Case," August 29, 2014
- ↑ Wisconsin Bar Association, "Warrant to Track Suspect’s Cell Phone Met Constitutional Requirements," September 9, 2014
- ↑ United States District Court for the Eastern District of Wisconsin Milwaukee Division, "Eric O’Keefe, and Wisconsin Club for Growth, Inc.," accessed February 23, 2015
- ↑ Wisconsin State Journal, "Supreme Court ends John Doe probe that threatened Scott Walker's presidential bid," July 16, 2015
- ↑ 41.0 41.1 Supreme Court of Wisconsin, "PETITION FOR SUPERVISORY WRIT BEFORE THE SUPREME COURT, APPEAL AND BYPASS TO THE SUPREME COURT FROM CIRCUIT COURT ORDER," July 16, 2015
