Background
Chad R. Sprenger pleaded no contest to first-degree reckless homicide and two counts of substantial battery after his infant daughter died from injuries he inflicted. The child had suffered earlier injuries in August 2001, including leg and rib fractures. After initially blaming Sprenger’s mother, Sprenger later admitted he had caused those injuries. In March 2002, he admitted throwing his daughter onto a hardwood floor after becoming angry when she cried; she died four days later.
At sentencing, Sprenger disclosed that he was being treated for depression and had taken prescribed medications. He had been taking the SSRI Zoloft for about a year when the March 2002 incident occurred. The circuit court imposed consecutive sentences totaling 32 years of initial confinement and 21 years of extended supervision, emphasizing the gravity of the offenses, the repeated violence over seven months, and Sprenger’s lies, blame-shifting, and failure to seek help or protect his daughter.
The Court’s Holding
The Wisconsin Court of Appeals affirmed the denial of Sprenger’s 2023 motion for sentence modification based on a new factor. Sprenger relied on later-published studies suggesting that SSRIs may cause violent behavior in some people, particularly younger patients, and on institutional records he said reflected more anxiety and aggression while taking Zoloft.
A new factor must be highly relevant to the sentence imposed. Even assuming the new material could explain Sprenger’s violence, the court held it did not address the sentencing court’s central concerns: his repeated violence over months, his dishonesty, his effort to blame others, and his failure to act to protect his daughter despite opportunities to do so. Because the SSRI evidence was not highly relevant to the factors that actually drove the original sentence, it was not a new factor as a matter of law.
Key Takeaways
- New information must bear directly on factors the sentencing court actually relied on.
- Potential evidence explaining violent conduct did not undermine the aggravating circumstances emphasized at sentencing.
- Without a qualifying new factor, a court need not decide whether sentence modification is warranted.
Why It Matters
The decision underscores that a new-factor claim is tied to the original sentencing record, particularly the sentencing court’s stated reasons. Evidence that might contextualize an offense will not support modification when it does not materially affect the aggravating circumstances that drove the sentence.