State of Wisconsin, Plaintiff-Appellant v. James R. Thiel, Defendant-Respondent-Petitioner

Summary

The Wisconsin Supreme Court held that Thiel received ineffective assistance of counsel because counsel failed to review discovery, conduct necessary investigation into the complainant's credibility, and correctly understand and invoke the statutory procedure governing evidence of the complainant's personal and medical history. Although no single deficiency independently established prejudice, the court held that their cumulative effect undermined confidence in the reliability of the trial and warranted a new trial. The court also held that ineffective-assistance claims are reviewed de novo on legal questions, while historical facts receive deference unless clearly erroneous.