State v. Guerard

¶ 1 This case concerns the corroboration requirement for the admission of a hearsay statement against penal interest under Wis. Stat. § 908.045(4) (2001-02).1 The issue arises in the context of a claim of ineffective assistance of trial counsel.

¶ 2. The defendant was convicted of numerous serious felonies in connection with a home-invasion assault, robbery, and theft of guns. The defendant was identified in photo arrays and a line-up by the victim and an eyewitness who was present in the home at the time of the crimes. However, the defendant's brother told his sister and an investigator for…