939.31 and conspiracy as a theory of prosecution for a substantive crime under sub. (2) (c). State v. Jackson, 2005 WI App 104, 281 Wis. 2d 137, 701 N.W.2d 42, 041603. The unanimity requirement was satisfied when the jury unanimously found that the accused participated in the crime. Lampkins v. Gagnon, 710 F.2d 374 (1983). This section does not shift the burden of proof. The prosecution need not specify which paragraph of sub. (2) it intends to proceed under. Madden v. Israel, 478 F. Supp. 1234 (1979). Liability for Coconspirator’s Crimes in the Wisconsin Party to a Crime Statute. Schuessler. 66 MLR 344 (1983). Application of Gipson’s Unanimous Verdict Rationale to the Wisconsin Party to a Crime Statute. Baumgarth. 1980 WLR 597. Wisconsin’s Party to a Crime Statute: The Mens Rea Element Under the Aiding
May 22, 2026, are designated by NOTES. (Published 5-22-26)
3
Updated 23-24 Wis. Stats.
and Abetting Subsection, and the Aiding and Abetting-Choate Conspiracy Distinction. Ostos-Irwin. 1984 WLR 769.