§ 974.06 Serial Litigation: Defendant Represented by Trial Counsel on Prior, Direct Appeal

State v. Spriggie Hensley, Jr., 221 Wis. 2d 473, 585 N.W.2d 683 (Ct. App. 1998)
For Hensley: Pro se

Issue/Holding: The rule that a defendant’s representation by the same attorney at trial and on direct appeal constitutes a “sufficient reason” for not asserting ineffective assistance of counsel in the direct appeal survives State v. Escalona-Naranjo, 185 Wis.2d 168, 517 N.W.2d 157 (1994).