In State v. Hughes, 218 Wis. 2d 538, 543, 582 N.W.2d 49 (Ct. App. 1998), the Court was required to interpret and apply Wis. Stat. 943.20(3)(d)2. Hughes pled guilty to theft from a person, party to a crime, based on a criminal complaint stating that he or an accomplice took the victim's purse from the handle on the back of her wheelchair and fled. See Hughes, 218 Wis. 2d at 540. Hughes argued that the complaint provided an insufficient factual basis for his plea because it did not establish that he or his accomplice took the purse "from the person" of the victim. Id. The Court concluded "that theft 'from the person' encompasses the taking of property from the wheelchair of one sitting in the wheelchair at the time of the taking." 218 Wis. 2d at 548. In Hughes, the Court held that the words "from the person" in Wis. Stat. 943.20(3)(d)2 were ambiguous because courts from other jurisdictions had conflicting views of similar laws, some adopting "a narrow view of the connection between victim and property" and some adopting "a broader standard." 218 Wis. 2d at 541, 544. The Court reviewed the legislative history of the statute, concluding that it "indicates the legislature's intent to enact a theft from person statute that enhances the penalty for takings that are 'particularly dangerous or undesirable.'" 218 Wis. 2d at 545 n.7.