State v. Haugen

While further facts were elicited during the course of trial, they are immaterial to the determination of whether the complaint was sufficient to show probable cause that a crime had been committed and that Haugen had probably committed it.

Evidence adduced at a subsequent trial cannot be used to supply the factual deficiencies of a complaint. As we frequently held, a complaint, including documents that are made a part of it by reference, is a self-contained charge, and it alone may be considered in determining probable cause. State ex rel. Cullen v. Ceci (1970), 45 Wis. 2d 432, 173 N. W. 2d…