State v. Spaeth
In State v. Spaeth, 206 Wis. 2d 135, 556 N.W.2d 728 (1996), repeated convictions for operating after revocation (OAR) were a sentencing issue, the court concluded that "competent proof must reliably demonstrate, with particularity, the existence of each prior OAR conviction." Spaeth, 206 Wis. 2d at 150, 556 N.W.2d at 734.
The court instructed that the State may prove the prior convictions through "reliable documentary proof." Spaeth, 206 Wis. 2d at 148, 556 N.W.2d at 733-34.
The court included within the definition of competent proof a copy of the defendant's DOT driving record. See Spaeth, 206 Wis. 2d at 153, 556 N.W.2d at 735.