In 2003, Officer Steven E. Kraus was demoted from his probationary promotion to sergeant back to patrol officer due to performance issues. Kraus contested the demotion, arguing he was entitled to a ‘just cause’ hearing under Wisconsin Statute § 62.13(5)(em). The Wisconsin Supreme Court ruled that such a hearing was not required for demotions during probationary periods based on performance evaluations, as they are considered non-disciplinary actions.
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