Hayes v. State
In Hayes v. State, 46 Wis. 2d 93, 101, 175 N.W.2d 625 (1970), the court adopted the rule that a trial court had the power to change or modify a sentence after the execution of the judgment had commenced and the term ended.
It imposed the same time limit for bringing a motion to modify a sentence as the statutory time limit for a postconviction motion for a new trial-one year from the date of sentencing; but, because the criminal code changed beginning July 1, 1970, the time limit was changed to ninety days. See id. at 106.