In State v. Cobbs, 221 Wis. 2d 101, 584 N.W.2d 709 (Wis. Ct. App. 1998), defense counsel had previously prosecuted the defendant when he was working in the district attorney's office. The Wisconsin Supreme Court found there was no actual conflict of interest or serious potential conflict of interest. Id. at 711. The court pointed out that "there were no competing loyalties in this case," nor was it "a situation where defense counsel has appeared for and represented the State as a prosecutor in prior proceedings involving the same case in which he or she currently represents the defendant." Id.