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Ineffective Assistance of Counsel

Frank V. Blonda appeals a judgment of conviction for substantial battery with intent to do bodily harm in violation of WIS. STAT. § 940.19(2)(2015-16) and disorderly conduct in violation of WIS. STAT. § 947.01(1), with both crimes being subject to the domestic abuse enhancer of WIS. STAT. § 968.075(1)(a), and the order denying his motion for postconviction relief.

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Duty to Defend

This appeal illustrates a recur‐ ring issue for liability insurers and their insureds: how to determine whether the insurer owes a duty to defend its insured when a claim is first asserted against the insured, before the insurer knows the underlying facts.

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Confrontation Clause

We review a published opinion of the court of appeals,1 which determined that use of a deceased police officer's recorded statements at a suppression hearing did not violate Glenn T. Zamzow's rights under the Confrontation Clause of the Sixth Amendment or the Due Process Clause of the Fourteenth Amendment to the United States Constitution.

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