| Court: | Supreme Court of Wisconsin |
| Facts: | Not too many are given. Evanow was implicated in burglarious conduct by some accomplices, one of whom was a police officer. He was evidently convicted (or pled guilty to) burglary, but appealed on the basis that the charge was invalid. |
| Posture: | Appeal previously heard in Milwaukee Circuit Court. |
| Issue: | Whether the written criminal complaint in the case was sufficient to constitute probable cause for the charge of burglary. |
| Holding: | The complaint may have been lame, but it was sufficient because it had the essential facts (who, what, where, when, why, and who said so). Affirmed. |
| Rule: | There must be facts in the complaint that are sufficient, or give rise to reasonable inferences sufficient to establish probable cause. |
| Reasoning: | The defendant's believes the requirements for a criminal complaint involve complete detail, and the information should be scrutinized the way evidence at trial is. These are wrong beliefs: the complaint seeks only to establish probable cause, not defeat reasonable doubt. For this, we don't need every last detail-- only those which are essential contributors to probable cause. Moreover, the credibility of evidence is to be decided at trial, and this is not a sort of pre-trial. This particular complaint, while imperfect, did set forth the necessary information to support a charge. |
| Dicta: | It would be too much to require that self-identified partners in a burglary be established to be pillars of the community or leaders in the scout movement before their admissions could be found to have the ring of truth. |