State v. Edward J. Zimbal

¶ 54.

PATIENCE DRAKE ROGGENSACK, C.J.

0concurring). Although I would reverse the decision of the court of appeals and remand for the assignment of a different circuit court judge to preside at Zimbal's trials, I respectfully concur in, but do not join, the majority opinion. The majority opinion's standard, which cases have described as "relaxing]" the rule of strict compliance with Wis. Stat. § 971.20(7),1 is too amorphous to provide guidance in future cases where a circuit court's interaction with an unrepresented defendant contributes to temporal problems with statutory compliance.

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