State v. Escalona-Naranjo
In State v. Escalona-Naranjo, 185 Wis. 2d 169, 517 N.W.2d 157 (1994), the Court held that "a motion under sec. 974.06 could not be used to review issues which were or could have been litigated on direct appeal." Escalona-Naranjo, 185 Wis. 2d at 172.
The statute, however, does not preclude a defendant from raising "an issue of constitutional dimension which for sufficient reason was not asserted or was inadequately raised in his original, supplemental or amended postconviction motions." Escalona-Naranjo, 185 Wis. 2d at 184.