State v. Conner, 795 N.W.2d 750

Conner was charged in 2005 with two counts of stalking with a previous conviction within seven years and one count of criminal damage to property, tied to a November 30, 2005 incident.
The charging documents incorporated attached materials listing 27 dates of alleged acts beginning in 2000, and described a course of conduct.
Conner had prior 2003 convictions for harassment-related offenses involving the Gainors, plus other prior convictions.
At trial, evidence included acts from 2000–2005, including uncharged acts admitted as other-acts evidence and acts tied to the Gainors.
The court of appeals affirmed the conviction, holding the notice was adequate and the seven-year requirement for Class H felony was satisfied by a continuing course of conduct.
The Wisconsin Supreme Court granted review to address (1) adequate notice for the course-of-conduct element and (2) the interpretation of the seven-year requirement under § 940.32(2m)(b).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether charging documents provided adequate notice for the course of conduct element.	Conner argues notice was insufficient because only a single November 30, 2005 incident was charged.	The State contends a complaint may incorporate attached documents listing dates, giving proper notice.	Yes; notice was constitutionally adequate.
Whether the 'present violation' within seven years after a prior conviction can be satisfied by a continuing course of conduct including acts before the prior conviction.	Conner contends the seven-year requirement limits the course of conduct to acts after the 2003 conviction.	The State argues the seven-year window applies to the final act, while earlier acts can form the course of conduct.	Yes; the seven-year limit applies to the final act, and a continuing course may include earlier acts.

State v. George, 69 Wis. 2d 92 (Wis. 1975) (notice inadequate where counts cover long periods without specific acts)
State v. Kaufman, 188 Wis. 2d 485 (Wis. Ct. App. 1994) (continuing offenses must be alleged with a proper time frame)
Holesome v. State, 40 Wis. 2d 95 (Wis. 1968) (two-part Holesome notice test for charging offenses)
State v. Warbelton, 315 Wis. 2d 253 (Wis. 2008) (continuum of stalking offenses across degrees of severity)
State v. George, (additional reference), 230 N.W.2d 253 (Wis. 1975) (context for notice and multiplicitous/duplicitous charging)
John v. State, 96 Wis. 2d 183 (Wis. 1980) (notice when information tracks prior related misconduct)