“But release me from my bands
With the help of your good hands …
As you from crimes would pardoned be,
Let your indulgence set me free.”

— Prospero, Shakespeare’s The Tempest, Act V Epilogue, lines 9-10, 19-20

“Good nature and good sense must ever join;
To err is human; to forgive, divine.”

— Alexander Pope, An Essay on Criticism Part II (1711)

Situation: C.J., a 17-year-old whose prefrontal cortex is still developing,^[1] acts impulsively and makes some bad choices, including shoplifting, getting into a fight at school, and possessing marijuana. They take responsibility and enter a plea in adult criminal court, as Wisconsin is one of only four U.S. states that automatically prosecutes 17-year-olds as adults.^[2] At sentencing, the judge authorizes expungement upon successful completion of probation. C.J. takes probation seriously and receives a successful discharge without any rule violations. The conviction is expunged. There are no issues with job applications, college admissions, military enlistment, housing, and so on, right? Not so fast.

In this two-part series on expungement in Wisconsin, part one explores the current state of the law in two sections. The first section sets forth the statutory text and legislative history governing the expungement of criminal convictions and juvenile delinquency adjudications. The second analyzes case law to clarify what expungement does and does not do, distinguishing which records do and do not go away and critically examining the three “substantial advantages” of expungement that Wisconsin appellate courts have asserted. Drawing on the author’s courtroom experience, part 2 of this series provides lawyers with 10 practical pointers to help clients pursue expungement and proposes specific legislative changes to make expungement work better in Wisconsin.

Expungement — Statutory Text and Legislative History

Wisconsin Statutes section 973.015 (“Special disposition”) governs expungement for criminal convictions.^[3] Wis. Stat. section 938.355(4m) (“Expungement of record”) governs expungement for juvenile delinquency adjudications. To be eligible for expungement of a criminal conviction, all six of the following criteria must be met:

1. The offender must be under 25 on the date the offense was committed (or under 18, for certain invasion-of-privacy offenses).^[4]

2. The offender cannot have a prior felony conviction.

3. The maximum period of imprisonment is six years or less (a Class H felony or less serious offense).^[5]

4. The crime is nonviolent and not on a short list of ineligible offenses.^[6]

5. At the time of sentencing, the court determines, in its discretion, that the person will benefit and that society will not be harmed by this disposition. It then orders the record expunged upon successful completion of the sentence.

6. The offender successfully completes the sentence by not being convicted of a subsequent offense and, if placed on probation, by satisfying the conditions of probation (examined in depth in part two in the series).

To be eligible for expungement of a juvenile delinquency adjudication, all three of the following criteria must be met:

1. The juvenile must wait until they turn 17 before petitioning the court to expunge its record of the adjudication.

2. The court must determine that the juvenile has satisfactorily complied with the conditions of the dispositional order.

3. The court must determine that the juvenile will benefit from, and society will not be harmed by, the expungement.

The legislative history shows tension in balancing justice with mercy: on the one hand, lawmakers keep adding disqualifying offenses; on the other, the Wisconsin Legislature has expanded eligibility for expungement, most critically by lowering the age from 25 to 21 and allowing not only misdemeanors but also low-level felonies.^[7]

Case Law on Expungement: What Expungement Does and Does Not Do

On the surface, these expungement statutes look great. If youthful offenders meet the statutory criteria, they can have their records, including low-level felonies, seemingly wiped clean. Unfortunately, neither Wis. Stat. section 973.105 nor Wis. Stat. section 938.355(4m) defines “to expunge” (or “expungement”). There is also little citable case law on juvenile expungement.^[8] But in a few published opinions, courts have interpreted this key word in ways that help but also give defendants unfounded hope.

In a 1991 published decision, State v. Anderson, the Wisconsin Court of Appeals was “persuaded by the trial court’s logic” that barred the use of an expunged conviction to impeach a witness; the trial court had found that the purpose of expungement is “to, in effect obliterate the record of the individual … their records should also have been destroyed.”^[9] The appellate court further noted that the legislature had failed to amend Wis. Stat. section 973.015 after the attorney general’s opinion in 67 Op. Att’y Gen. 301 (1978), which stated that the practice of placing a record in a sealed envelope and labeling it “expunged,” but not destroying it, did not comply with the “common and ordinary meaning of the word ‘expunge.’”^[10] The Anderson court explained that “[t]he word ‘expunge’ was to be construed according to its common and approved usage. Black’s Law Dictionary 582 (6th ed. 1990) defines ‘expunge’ as follows: ‘To destroy; blot out; obliterate; erase; efface designedly; strike out wholly. The act of physically destroying information—including criminal records—in files, computers, or other depositories.’”^[11] After Anderson, the Wisconsin Supreme Court issued Order No. 97-07 on November 3, 1997, creating SCR 72.06, which commands the clerk of the court, after the court orders expungement, to “destroy” the expunged court records.^[12]

In its 2002 decision in State v. Leitner, the Wisconsin Supreme Court clarified that the statements in Anderson that the prosecutor should have destroyed their records were dicta and should be accorded no weight: Wis. Stat. section 973.015 authorized expunging court records only, so district attorneys and law enforcement agencies did not have to destroy their own records regarding expunged convictions.^[13] The court also declared, “Expunction of a court record of a conviction enables an offender to have a clean start so far as the prior conviction is concerned. As the State points out, expunging the court record provides substantial advantages to the offender. An expunged record of a conviction cannot be considered at a subsequent sentencing; an expunged record of a conviction cannot be used for impeachment at trial under § 906.09(1); and an expunged record of a conviction is not available for repeater sentence enhancement.”^[14]

The Wisconsin Supreme Court unanimously clarified key procedural mechanics of expungement in favor of criminal defendants in a 2014 decision, State v. Hemp (discussed in part two).^[15] Echoing language in Leitner about a “clean start,” the Hemp court wrote: “Expungement offers young offenders a fresh start without the burden of a criminal record and a second chance at becoming law-abiding and productive members of the community. Expungement allows individual defendants a chance to move past the barriers that can be created by a criminal record by giving them an incentive to rehabilitate, which, in turn, promotes public safety. Indeed, expungement allows offenders to present themselves to the world—including future employers—unmarked by past wrongdoing.”^[16]

In reality, as discussed below, the “substantial advantages” described in Leitner are mostly illusory (especially for drug convictions), and the inspiring words from Leitner about a “clean start” and from Hemp about a “fresh start … second chance … to move past the barriers … unmarked” remain aspirational. Even after expungement, there is no true clean or fresh start. Not only can prosecutors and law enforcement retain these records, but so can the Wisconsin Department of Transportation (DOT) in operating while intoxicated cases. Moreover, Wisconsin appellate courts have consistently held that expungement removes only the public court record, not the fact of the criminal conviction.^[17] For many crucial purposes, the mark of past wrongdoing remains — maybe not as public as a scarlet letter but still a formidable barrier for young offenders seeking to move forward in their lives, including in employment, education, housing, military service, and self-defense. For too many young people, the path to their human and professional fulfillment remains largely blocked.

CCAP, Clerk of Courts, and CIB: Some Records Go Away, Some Do Not

The most immediate and tangible benefit of expungement, especially in this increasingly digital age, is removing the conviction from searchable online public records, chiefly Wisconsin Circuit Court Access (commonly known as CCAP).^[18] Expungement also removes public access to the official court file held by the local clerk of courts, which, given mandatory e-filing and the digitization of old physical court files, often amounts to removing the case from CCAP.^[19] For juvenile delinquency adjudications, however, expungement does not offer this benefit of scrubbing CCAP. Juvenile records are already highly confidential under Wis. Stat. section 938.78 (“Confidentiality of records”); they should not be on CCAP in the first place.

For the average member of the public, the expunged conviction appears to be out of sight and out of mind. This is good because despite the warning language on the CCAP opening webpage about possible employment discrimination based on arrest or conviction records,^[20] it is difficult to prove that a potential employer refused employment on that basis alone and that the arrest or conviction was not substantially related to the job. Thus, removing a prior conviction from the disapproving gaze of potential employers, customers, renters, sellers, and so on, can be crucial for a defendant seeking to make a fresh start and move past the barriers posed by a criminal conviction.

However, just because the conviction does not appear on CCAP and has been sealed by the clerk of courts does not mean it is gone. As discussed above, prosecutors, law enforcement, and the DOT can keep their records from expunged cases, so for a modest fee ($12) anyone—a potential landlord, employer, higher education official, or others—can request a person’s Wisconsin criminal history from the Wisconsin Department of Justice (DOJ), Division of Law Enforcement Services, Crime Information Bureau (CIB), Record Check Unit.^[21] As the DOJ notes, Wisconsin adult criminal history data is public information, so Wis. Stat. sections 19.35(1) (“Access to records; fees”) and 165.82 (“Criminal history search fee”) allow any person or entity to request a criminal background check on another person. Thus, expungement makes some records go away, but not all: yes, to CCAP and the clerk of courts, but no, to the CIB. This access does not offer the fresh start that expungement was legislatively intended to provide.

No Regular Repeater Enhancement, but Not So for Drug Offenses

Of the three “substantial advantages” that Leitner outlines, the third — that an expunged record of a conviction is not available for repeater sentence enhancement — has the most value to defendants and is the only one that is substantial. Wis. Stat. section 939.62(2), which is the “regular” repeater statute for increased penalties for repeat offenders and has a five-year look-back period, requires that prior convictions “remain of record and unreversed.”^[22] If there is no longer an official court record, unless the defendant stipulates to the prior conviction, it is difficult, if not impossible, for the state to prove beyond a reasonable doubt, as it must, that a prior conviction of record exists for enhancement.^[23]

The situation is different for drug offenses. There is no such language (“of record”) in either type of enhancement for repeat drug offenses. Wis. Stat. section 961.48 (“Second or subsequent offenses”) enhances the penalty for drug crimes that are already felonies, such as offenses involving narcotic drugs like heroin and fentanyl.^[24] Unlike the regular repeater enhancer, for this second and subsequent drug offense repeater, there is no requirement that the prior conviction be “of record and unreversed.” Instead, section 961.48 merely requires a prior conviction^[25] for any type of prior drug offense, committed at any point in the defendant’s past. It is not limited to drug offenses within the past five years, even for possession of drug paraphernalia (maximum penalty 30 days’ jail and a $500 fine).^[26]

Under another drug-offense-enhancement statute, Wis. Stat. section 961.41(3g), possession of specific nonnarcotic drugs — cocaine, certain hallucinogenic and stimulant drugs, THC, and synthetic cannabinoids — becomes a Class I felony (maximum penalty three and a half years’ imprisonment) if the defendant has any prior drug conviction, at any point in their past. As with Wis. Stat. section 961.48, that prior conviction can be for something as minor as possession of drug paraphernalia, and there is no requirement that the prior drug conviction be “of record and unreversed.”^[27]

The legislature could have included the “of record and unreversed” language in either or both drug repeater statutes, but it did not. Consider the possible consequences. A police officer pulls over a vehicle for a minor traffic violation, such as failing to use a turn signal when required. The vehicle is full of 17-year-old high school students, and the officer finds a pot pipe inside the vehicle. The state charges everyone in the vehicle with possession of drug paraphernalia, party to a crime. One of the occupants takes responsibility and enters a plea, after which the circuit court orders expungement. The person completes probation without a single rule violation, so the conviction is expunged. Decades later, that person, who has otherwise led a crime-free life, is caught with THC that the person has been using medicinally. There appears to be nothing stopping the state from charging the Class I felony offense of possession of THC, second and subsequent offense.

At trial, unlike with the “regular” repeater, the state does not have to prove the existence of a prior drug conviction beyond a reasonable doubt.^[28] Instead, at sentencing, the court can simply ask the defendant whether the defendant has a specific prior drug conviction.^[29] If the defendant does not say anything (“stands mute”) or denies the conviction, (1) a certified copy of the conviction can be presented to the circuit court; (2) the case jacket itself may be presented if it is from the same county where sentencing is being done; or (3) the proof can be made by an official report of the FBI or any other governmental agency of the United States or Wisconsin or any other state that is specific enough to identify the defendant, the felony, and the date of conviction.^[30] Thus, even if the official court record of the prior drug conviction is expunged, law enforcement agencies or prosecutors do not have to destroy records relating to an expunged conviction; they can keep their own records.^[31]

In sum, expungement removes the state’s ability to use the “general” repeater enhancer but not the repeat drug offense enhancer. For drug cases, even marijuana, there is no fresh start.

No Impeachment as a Witness

As to the second advantage of expungement, the Anderson case discussed above interpreted the evidentiary rule in Wis. Stat. section 906.09(1) (“Impeachment by evidence of conviction of crime or adjudication of delinquency”) to mean that a party cannot use an expunged conviction to impeach a witness’s character for truthfulness at trial.^[32] By logical extension, this bar also applies to an expunged juvenile delinquency adjudication. However, this 1991 decision predates consistent case law holding that expungement does not remove the fact of the conviction, only the public court record, and not law enforcement records. Furthermore, like the drug repeater statutes discussed above, Wis. Stat. section 906.09(1) does not use the language of the “regular” repeater statute requiring that a prior conviction or adjudication be “of record and unreversed.” If the legislature had wanted to make expunged priors inadmissible as evidence, it could have written the statute to say so. Logical rigor and consistency demand that an expunged conviction be allowable for impeachment.

For now, though, expunged priors are off-limits for impeachment testimony at trial. Thus, a witness could avoid some public embarrassment, especially if they have had no other criminal convictions or juvenile adjudications. This might benefit the party calling the witness, but it is more face-saving than life-changing for a youthful offender.

Expungement Does Not Help Defendant at Future Sentencing

The first purported advantage of expungement mentioned by the Leitner court, that an expunged conviction cannot be considered at a subsequent sentencing, carries little weight in its current application. Later in the same opinion, the court held that “nothing in the language or history of § 973.015 indicates that the legislature intended record expunction under § 973.015 to wipe away all information relating to an expunged record of a conviction or to shield a misdemeanant from all of the future consequences of the facts underlying a record of a conviction expunged under § 973.015.”^[33] In other words, even though the expunged record itself cannot be considered, circuit courts can still use the facts underlying that conviction against a defendant at a later sentencing.^[34] This is not an advantage to the defendant. Indeed, this author has heard prosecutors argue, both in plea negotiations and at sentencing, that a defendant’s expunged prior conviction is a negative factor supporting a harsher penalty (a “spare the rod, spoil the child” argument).

As an analogy, consider accident forgiveness in auto insurance. An insurance policy promises that after five years, the insurer will not hold against the insured any official DOT record of a moving violation or any official proof of fault in a collision (for example, a docketed civil judgment); however, the insurer remains free to use against the insured, for all time, the underlying law enforcement reports showing bad driving. That is neither forgiving nor forgetting. It is form over substance.

Conclusion

In sum, expungement does not offer substantial advantages to young criminal defendants. While it removes the conviction record from CCAP and clerks of courts, anyone can still readily access a person’s entire criminal history from the Wisconsin DOJ for a modest fee. Expungement blocks the state from using the conviction for the “regular” repeater enhancer, but not for the lifetime drug offense enhancer. Although current law shields an expunged conviction from impeachment use, that shield is inconsistent with case law holding that expungement does not remove the fact of conviction, only the public court record. And a subsequent sentencing court can still rely on the facts underlying an expunged conviction. On balance, expungement is mostly aspirational and does not provide the fresh start the statute intended. The next part in this series offers practical pointers for attorneys to help their clients with expungement and proposes legislative reforms to make expungement work in Wisconsin.

Endnotes:

[1] See Nat’l Inst. of Mental Health (NIMH), The Teen Brain: 7 Things to Know, https://www.nimh.nih.gov/health/publications/the-teen-brain-7-things-to-know. (last visited June 24, 2026). NIMH is part of the National Institutes of Health, a component of the U.S. Department of Health and Human Services. ^

[2] The other three states are Georgia, Texas, and Louisiana. See Olivia Naugle, Automatically Charging Youth as Adults, The Sentencing Project (Dec. 11, 2025), https://www.sentencingproject.org/policy-brief/automatically-charging-youth-as-adults/. ^

[3] The statute uses the verb “expunged,” and case law uses the nouns “expungement” and “expunction.” The Wisconsin Supreme Court Rules (SCR 72.06) use “expunction.” Wis. Stat. section 938.355(4m) uses “expungement.” This article uses “expungement.” ^

[4] Wis. Stat. § 942.08(2)(b), (c), or (d), or (3). Expungement is mandatory in these cases if the defendant successfully completes the sentence. ^

[5] Wis. Stat. section 301.048(2)(bm) includes not only traditionally violent crimes but also certain other offenses and certain crimes against children. ^

[6] For Class H felonies, the Class H version of stalking, Wis. Stat.§ 940.32(2m); the Class H offense of intentionally causing bodily harm to a child, Wis. Stat. § 948.03(2)(b); the Class H offense of recklessly causing bodily harm to a child, Wis. Stat. § 948.03(3)(c); or any of the five varieties of engaging in repeated acts of physical abuse of the same child, Wis. Stat.§ 948.03(5) 1.-5. (which are not Class H felonies anyway); and sexual assault of a child by a school staff person or a person who works or volunteers with children, Wis. Stat. § 948.095. For Class I felonies, concealing or not reporting the death of an unborn child, Wis. Stat. § 948.23(1)(a). Thus, the Class I versions of stalking, Wis. Stat. § 930.32(2) and (2e), are eligible for expungement, as is the Class I version of recklessly causing bodily harm to a child, Wis. Stat. § 948.03(3)(b). ^

[7] Chapter 39, Laws of 1975 (1975 Assembly Bill 222, the executive budget bill) created Wis. Stat. section 973.015, “Misdemeanors, special disposition,” which took effect July 1, 1976. 1983 Wis. Act 519 then added the requirement to satisfy probation conditions. 1995 Wis. Act 77, § 629, substantially revised the Children’s Code and created Wis. Stat. section 938.355(4m). 2003 Wis. Act 33 exempted Department of Transportation (DOT) records. 2003 Wis. Act 50 added a list of voyeuristic crimes eligible for mandatory expungement upon successful completion of the sentence if the defendant was under 18 at the time of the offense. Wis. Stat. § 942.08(2)(b), (c), or (d). 2003 Wis. Act 50 also created Wis. Stat. section 973.015(3), which states that expungement is not a basis for a claim for exoneration compensation (under Wis. Stat. section 775.05, “Compensation for innocent convicts”). 2009 Wis. Act 28 raised the eligible age from 21 to 25 and expanded the eligible offenses from misdemeanors (maximum 12 months’ jail) to low-level felonies. 2011 Wis. Act 268 amended Wis. Stat. section 948.23(1)(a) (Wis. Stat. section 948.23 is titled “Concealing or not reporting death of a child; not reporting disappearance of a child”) and added it to the list of crimes ineligible for expungement. 2013 Wis. Act 362 added an avenue for persons convicted of violating Wis. Stat. section 944.30 (“Prostitution”) to seek expungement at any time postconviction if they prove that they were victims of commercial sex trafficking at the time of the prostitution. Wis. Stat. § 973.015(2m). 2015 Wis. Act 80 added Wis. Stat. section 942.08(3) (an offense often referred to as “upskirting”) to the list of youthful voyeuristic crimes eligible for mandatory expungement upon successful completion of the sentence if the defendant was under 18 at the time of the offense. 2015 Wis. Act 366 added engaging in repeated acts of physical abuse of the same child to the list of crimes ineligible for expungement. Wis. Stat. § 948.03(5)(a)1., 2., 3., or 4. However, none of these four categories of child abuse are Class H or I felonies. Since then, bipartisan expungement reform bills with broad public support have passed the State Assembly but died in the State Senate: 2021 Assembly Bill 69 (https://docs.legis.wisconsin.gov/2021/proposals/ab69) and 2023 Assembly Bill 37 (https://docs.legis.wisconsin.gov/2023/related/proposals/ab37). Both bills had broad community support, including from the State Bar of Wisconsin. ^

[8] Of the eight appellate cases that cite Wis. Stat. section 938.355(4m), five concern Wis. Stat. section 973.015 and cite the juvenile statute for contrast. Of the remaining three cases, one is uncitable even for persuasive purposes (a no-merit report), and the second, though unpublished and citable as persuasive, is fact-specific (the trial court properly exercised discretion in denying juvenile expungement for an adjudication for repeated sexual assault of a child). The third case, though published, is dated, so the issue is not likely to arise. State v. Jason J.C. (In the Int. of J.C., 216 Wis. 2d 12, 573 N.W.2d 564 (Ct. App. 1997) (a review of the legislative history and statutory text showed that Wis. Stat. section 938.355(4m) is substantive and not remedial legislation, so the trial court was correct that it could not expunge 1994 adjudications; the statute applies only to violations occurring after July 1, 1996). One may reasonably infer that “satisfactorily complied with the conditions of his or her dispositional order” will be interpreted as Wisconsin appellate courts have interpreted the parallel condition in section 973.015 about successfully completing probation (discussed in part two of the series): not just discharging from supervision but avoiding a single violation of a rule that either the court or the department orders. ^

[9] State v. Anderson, 160 Wis. 2d 435, 441, 466 N.W.2d 681 (Ct. App. 1991). ^

[10] Id. ^

[11] Id. ^

[12] SCR 72.06 Expunction. “When required by statute or court order to expunge a court record, the clerk of the court shall do all of the following:
(1) Remove any paper index and nonfinancial court record and place them in the case file.
(2) Electronically remove any automated nonfinancial record, except the case number.
(3) Seal the entire case file.
(4) Destroy expunged court records in accordance with the provisions of this chapter.” ^

[13] State v. Leitner, 2002 WI 77, 253 Wis. 2d 449, 646 N.W.2d 341. ^

[14] Id. ¶ 22 (emphasis added). ^

[15] State v. Hemp, 2014 WI 129, 359 Wis. 2d 320, 856 N.W.2d 811. ^

[16] Id. ¶ 19 (emphasis added) (internal citations and quotation marks omitted). ^

[17] “Vacatur invalidates the conviction itself, whereas expunction of a conviction merely deletes the evidence of the underlying conviction from court records. Expunction, unlike vacatur, does not invalidate the conviction.” State v. Braunschweig, 2018 WI 113, ¶ 22, 384 Wis. 2d 742, 921 N.W.2d 199. Wis. Stat. section 973.015(2m) authorizes vacatur only for Wis. Stat. section 944.30 (“Prostitution”). See also Van Oudenhoven v. Wisconsin Dep’t of Just., 2024 WI App 38, ¶¶ 38-39, 413 Wis. 2d 15, 10 N.W.3d 402, review dismissed as improvidently granted, 2025 WI 25, 416 Wis. 2d 547, 21 N.W.3d 742, cert. denied sub nom., Oudenhoven v. Wisconsin Dep’t of Just., 146 S. Ct. 1635 (2026). ^

[18] By its own disclaimer, Wisconsin Circuit Court Access (formerly CCAP) is not 100% accurate and is not the official record of a criminal case. See State v. Bonds, 2006 WI 83, ¶ 46, 292 Wis. 2d 344, 717 N.W.2d 133 (“a CCAP report, by its own terms, is of questionable accuracy”). ^

[19] See also SCR 72.06 Expunction. ^

[20] See https://wcca.wicourts.gov. “It may be a violation of state law to discriminate against a job applicant because of an arrest or conviction record. Generally speaking, an employer may refuse to hire an applicant on the basis of a conviction only if the circumstances of the conviction substantially relate to the particular job. For more information, see Wisconsin Statute 111.335 and the Department of Workforce Development’s publication, Arrest and Conviction Records under the Law.” ^

[21] See https://www.wisdoj.gov/Pages/CriminalJusticeServices/criminal-background-check.aspx. “Anyone can access and obtain adult criminal history record information (criminal background check) after paying the required fee.” The fee is $12 for the public. If the request is for a caregiver, there is an additional $8 Department of Health Services fee. See https://www.wisdoj.gov/Law%20Enforcement%20Services/Single_Subject_DJ_LE_250.pdf. Form DJ-LE-250 (revised Oct. 2024). ^

[22] Id. ¶ 39 n.30 (emphasis added). ^

[23] When a defendant does not admit to habitual criminality, the state must prove the alleged repeater status beyond a reasonable doubt. State v. Theriault, 187 Wis. 2d 125, 522 N.W.2d 264 (Ct. App. 1994). ^

[24] But not methamphetamine, per Wis. Stat. section 961.48(5). The omission was likely a legislative oversight. ^

[25] Wis. Stat. § 961.48(3). ^

[26] State v. Moline, 229 Wis. 2d 38, 598 N.W.2d 929 (Ct. App. 1999). ^

[27] Wis. Stat. section 961.41(3g), (c), (d), (e), and (em) have identical language. ^

[28] State v. Miles, 221 Wis. 2d 56, 584 N.W.2d 703 (Ct. App. 1998). ^

[29] State v. Coolidge, 173 Wis. 2d 783, 795, 496 N.W.2d 701 (Ct. App. 1993), abrogated on other grounds by, State v. Tiepelman, 2006 WI 66, 291 Wis. 2d 179, 717 N.W.2d 1 (the “admission may be obtained simply by the court asking the defendant the direct question of ‘whether the defendant was convicted on a particular date of a specific crime’”). ^

[30] State v. Farr, 119 Wis. 2d 651, 660, 350 N.W.2d 640 (1984). ^

[31] See Leitner, 2002 WI 77, 253 Wis. 2d 449; Braunschweig, 2018 WI 113, 384 Wis. 2d 742. ^

[32] See Anderson, 160 Wis. 2d 435. See also Wis. JI—Criminal 325 Impeachment of Witness: Prior Conviction or Juvenile Adjudication (2018); Wis. JI—Criminal 327 Impeachment of Defendant as a Witness: Prior Conviction or Juvenile Adjudication (2018). As the jury instructions note in their respective Comments,“[t]he 1996 revision added ‘adjudicated delinquent’ to the instruction. Section 906.09 was amended by 1995 Wisconsin Act 77 to allow impeachment by evidence of juvenile adjudication.” ^

[33] Leitner, 2002 WI 77, ¶ 38, 253 Wis. 2d 449 (emphasis added). ^

[34] Id. ¶ 44. ^