On April 6, 2017, the Wisconsin Supreme Court in State v. Zamzow cited scholarship by Professor Sanders entitled Unbranding Confrontation as Only a Trial Right, 65 Hastings L.J. 1257 (2014).  State v. Zamzow involves whether the Sixth Amendment's Confrontation Clause applies at pretrial motion to suppress hearings. The Wisconsin Supreme Court cited Unbranding Confrontation as additional historical analyses of the purposes and function of the Confrontation Clause.