State v. Michael L. Cox

*781 *340 ¶ 1 Upon conviction of a felony, our statutes provide for imposition of a $250 deoxyribonucleic acid (DNA) analysis surcharge on the defendant. Before the legislature adopted 2013 Wis. Act 20 (Act 20), the relevant statute said the court "may" impose that surcharge. Now, however, the statute says the court "shall" impose the surcharge. The court of appeals certified Mr. Michael L. Cox's appeal to us so that we may determine whether the substitution of *341 "shall" for "may" means that circuit courts no longer have the discretion to waive the surcharge. We conclude that Act 20 eliminated that…