Neylan v. Vorwald
In Neylan v. Vorwald, 124 Wis. 2d 85, 95, 368 N.W.2d 648 (1985), the Wisconsin Supreme Court noted the United States Supreme Court's discussion in Link v. Wabash R.R. Co that it may not be necessary to provide actual notice and a hearing where a party has constructive notice through other means, for example by orders or rules of the court, as to what may be the specific consequences of his conduct. See 124 Wis. 2d at 90.
Consequently actual or constructive notice of the specific consequences for failing to prosecute an action will satisfy the due process concerns attending a dismissal for failure to prosecute. See 124 Wis. 2d at 92.