State v. Kelley L. Hauk, 2002 WI App 226
For Hauk: David D. Cook
Issue/Holding: State need not charge defendant with both bail jumping and underlying crime in order to obtain conviction for bail jumping (i.e., violating bond by committing crime). ¶¶14-18.
¶19 We therefore conclude that as long as there is evidence sufficient to allow a reasonable jury to conclude beyond a reasonable doubt that a defendant intentionally violated his or her bond by committing a crime, that evidence is not required to be in the form of a conviction for the underlying crime.
Court disavows earlier, broad definition of “crime” for purposes of bail jumping, see State v. West, 181 Wis. 2d 792, 796, 512 N.W.2d 207 (Ct. App. 1993); instead, definition of “crime” specified in § 939.12 is to be utilized. ¶18 n. 3.