State v. Anton R. Dorsey, 906 N.W.2d 158

Anton Dorsey was charged with multiple domestic-violence offenses (strangulation, battery, disorderly conduct, aggravated battery) arising from assaults on his then-girlfriend C.B.; he was convicted on three counts and sentenced.
The State sought to admit other-acts evidence: testimony from a former girlfriend, R.K., describing violent incidents in 2011; the circuit court permitted the testimony but excluded evidence of the convictions themselves.
Admission turned on interpreting the 2013 amendment to Wis. Stat. § 904.04(2)(b)1., titled "Greater latitude," which addresses admissibility of similar-act evidence in certain sensitive prosecutions, including domestic abuse.
The circuit court applied the Sullivan three-part test (permissible purpose, relevance, prejudice balancing) but stated the statute afforded "greater latitude" for domestic-abuse other-acts evidence, and admitted R.K.'s testimony for intent/motive.
The court of appeals affirmed on other grounds, applying a straight Sullivan analysis and finding the evidence admissible; the Wisconsin Supreme Court granted review to decide (1) the proper standard under the amended statute and (2) whether admission here was an erroneous exercise of discretion.
The Supreme Court held that § 904.04(2)(b)1 permits admission of similar domestic-abuse acts with greater latitude under a Sullivan framework, and that the trial court did not abuse its discretion admitting R.K.'s testimony.

Issue	Plaintiff's Argument	Defendant's Argument	Held
What standard governs admission of other-acts evidence under Wis. Stat. § 904.04(2)(b)1?	The amendment authorizes greater latitude: allow admission of similar acts in listed prosecutions under the greater-latitude common-law approach (within a Sullivan analysis).	The amendment does not change existing law; a straight Sullivan test (no special greater-latitude expansion) controls.	The statute permits admission of similar acts with greater latitude as that common-law term is applied within the Sullivan three-prong framework.
Was admitting R.K.'s testimony an erroneous exercise of discretion?	Evidence was proffered for permissible purposes (intent/motive), was sufficiently similar and relevant, and probative value was not substantially outweighed by unfair prejudice—cautionary instruction mitigated risks.	The other-acts were remote, involved a different victim, and unfairly bolstered the victim/created propensity inference.	The circuit court did not err: it applied the proper standard, reasonably found relevance and probative value, and reasonably concluded prejudice did not substantially outweigh probative value.

State v. Sullivan, 216 Wis. 2d 768, 576 N.W.2d 30 (Wis. 1998) (articulates the three-part test for admitting other-acts evidence)
State v. Davidson, 236 Wis. 2d 537, 613 N.W.2d 606 (Wis. 2000) (explains application of greater-latitude rule within Sullivan)
State v. Hurley, 361 Wis. 2d 529, 861 N.W.2d 174 (Wis. 2015) (discusses greater-latitude admission principles)
State ex rel. Kalal v. Circuit Court for Dane County, 271 Wis. 2d 633, 681 N.W.2d 110 (Wis. 2004) (governs statutory interpretation principles)
State v. Veach, 255 Wis. 2d 390, 648 N.W.2d 447 (Wis. 2002) (addresses relevance of intent and Sullivan step one)