State v. Rowan, 814 N.W.2d 854

Rowan was convicted after a March 13, 2008 incident involving a gun and threats to officers and medical staff.
The circuit court imposed an extended supervision condition allowing suspicionless searches for firearms by any law enforcement officer.
Rowan challenged the condition as violating Fourth Amendment and Wisconsin Const. art. I, § 11.
The court tied the condition to Rowan's history of violence, threats, and firearm possession, including gun purchases.
The appellate court certified questions to the Wisconsin Supreme Court on the legitimacy of the search condition and on sufficiency of the battery evidence.
The Supreme Court applied the Edwards/Oakley/Krebs framework and compared to Samson to assess reasonableness and relation to rehabilitation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Constitutionality of suspicionless firearm search condition	Rowan alleges Fourth Amendment/Art. I, §11 violation	Samson supports reasonableness of individualized condition	Condition not overly broad and reasonably related to rehabilitation
Sufficiency of evidence that officer acted in official capacity	Officer not employed to assist medical staff	Officer assisted in restraining a combative arrestee	Evidence supports officer acted in official capacity beyond reasonable doubt

Griffin v. Wisconsin, 483 U.S. 868 (1987) (probation searches under state interests; reasonableness under special needs)
Samson v. California, 547 U.S. 843 (2006) (suspicionless searches of parolees/under supervision; diminished privacy; public safety interests)
Edwards v. State, 74 Wis. 2d 79 (1976) (rehabilitation/public safety as goals of probation conditions)
State v. Oakley, 245 Wis. 2d 447 (2001) (extends Edwards framework to extended supervision conditions)
Krebs v. Schwarz, 212 Wis. 2d 127 (Ct. App. 1997) (probation conditions found constitutional when narrowly drawn and related to rehabilitation)
State v. Hayes, 2004 WI 80 (2004) (sufficiency of the evidence standard; deferential review of jury verdict)