State v. Albright
In State v. Albright, 96 Wis. 2d 122, 291 N.W.2d 487 (1980), the Wisconsin supreme court acknowledged that while a defendant has a due process right to testify at trial, that right does not fall within the category of fundamental rights "which can only be waived in open court on the record by the defendant." See id. at 130, 291 N.W.2d at 490-91.
The court concluded that although the decision to testify should be made by the defendant after consulting with counsel, nonetheless, "counsel, in the absence of the express disapproval of the defendant on the record during the pretrial or trial proceedings, may waive the defendant's right to testify." Id. at 133, 291 N.W.2d at 492.