Wis. Stat. § 801.05
Personal jurisdiction of Wisconsin courts: the cases that interpreted this section
198 citing cases reviewed of 285 in the citation index: 138 interpreted the section (annotated below), 60 cited it only in passing. Cases filed after 2026-05-11 may not have been reviewed yet.
Have a situation under Wis. Stat. § 801.05?
These notes show how courts have ruled. Ask about your specific facts and see which of these rulings apply, with citations you can check.
Wisconsin business activity
Section 801.05(4)(a) requires an out-of-state defendant to anticipate a financial benefit from Wisconsin for its advertising to qualify as solicitation in the state.
Knot Just Beads v. Knot Just Beads, Inc. · filed 2002-08-29(4)(a)
In order for solicitation activities in Wisconsin to trigger personal jurisdiction, the solicitor must anticipate receiving a financial benefit from the solicitation. ... Taking the evidence in the light most favorable to plaintiff, it is reasonable to infer that defendant anticipated financial benefits as the result of the listing, but not that it anticipated financial benefits from Wisconsin.Read the full opinion on CourtListener →
Under § 801.05(4)(a), sending product samples to Wisconsin manufacturers constitutes solicitation activity that can support personal jurisdiction when the local injury and foreign act requirements are met.
Wayne Pigment Corp. v. Halox · filed 2002-09-17(4)(a)
However, sending samples is a form of advertising or solicitation. Further, it is reasonable to infer that Halox sent the samples to Wisconsin manufacturers for the purpose of obtaining direct or indirect financial benefit. Halox is a commercial entity not an eleemosynary corporation. Thus, plaintiff has pled sufficient facts to satisfy the third requirement of § 801.05(4).Read the full opinion on CourtListener →
Section 801.05(1)(d) permits general jurisdiction over a nonresident whose Wisconsin activities are substantial and not isolated, including systematic and continuous business contacts.
HUNTER ENGINEERING COMPANY v. ACCU Industries, Inc. · filed 2002-10-10(1)(d)
A defendant’s activities in Wisconsin are “substantial and not isolated” when the activities are “systematic and continuous.” ... For the foregoing reasons, § 801.05(l)(d) applies and allows Wisconsin courts to exercise general jurisdiction over ACCU.Read the full opinion on CourtListener →
Section 801.05(1)(d) requires substantial and not isolated activities in Wisconsin to establish general personal jurisdiction.
Morris Material Handling, Inc. v. KCI Konecranes Plc · filed 2004-09-09(1)(d)
The Court is satisfied that KCI does not have sufficient contacts to satisfy Wisconsin's long-arm statute in light of due process concerns. Morris does not establish that KCI is involved in "substantial and not isolated activities in this state” for purposes of general jurisdiction.Read the full opinion on CourtListener →
Section 801.05(1)(d) provides personal jurisdiction when a defendant engages in substantial and not isolated activities in Wisconsin, assessed through the quantity, nature, source, state interest, and convenience factors.
Druschel v. Cloeren · filed 2006-08-01(1)(d)
In sum, we conclude that Cloeren engaged in "substantial not isolated activities" in Wisconsin, and Wis. Stat. § 801.05(l)(d) provides personal jurisdiction.Read the full opinion on CourtListener →
Section 801.05(1)(d) permits personal jurisdiction based on substantial, continuing Wisconsin activities, including repeated solicitation, trailer sales and in-state work, even when Wisconsin accounts for a small share of the defendant’s total sales.
Sentry Select Insurance v. McCoy Corp. · filed 2013-09-30(1)(d)
Wisconsin’s long-arm statute extends personal jurisdiction to nonresidents who are “engaged in substantial and not isolated activities within this state.” ... These undisputed facts by themselves make out a prima facie case of personal jurisdiction. ... Nowhere in the Wisconsin law or due process does personal jurisdiction hinge upon an analysis of the percentage of defendant’s own sales in the forum state.Read the full opinion on CourtListener →
Section 801.05(1)(d) permits general jurisdiction when a corporation’s regular stock sales, investor communications, and bank deposits in Wisconsin are substantial in quality and continuous and systematic in quantity.
Shepherd Investments International, Ltd. v. Verizon Communications Inc. · filed 2005-06-01(1)(d)
Taken together, defendant’s solicitations and sales of stock in Wisconsin, carried out through regular communications with its shareholders and through internet communications, its promotional activities carried out through the same means and through quarterly conference calls with financial analysts and institutional investors, and its regular deposits in Wisconsin banks amount to activities in Wisconsin that were both substantial in quality and continuous and systematic in quantity.Read the full opinion on CourtListener →
Section 801.05(1)(d) requires a defendant’s substantial, nonisolated Wisconsin contacts to exist when the action is commenced.
FL HUNTS, LLC v. Wheeler · filed 2009-12-15(1)(d)
Wisconsin Stat. § 801.05(l)(d) plainly requires the circuit court to analyze a defendant's contacts at the time the action is commenced.Read the full opinion on CourtListener →
A plaintiff invoking § 801.05(4)(a) must make a prima facie showing that solicitation in Wisconsin at the time of injury was carried on by or on behalf of the defendant.
Seebach v. Beetling Design Corp. · filed 2014-08-29(4)(a)
Nor do they establish that, at the time of the injury, the solicitation within this state was carried on by or on behalf of Beetling. ... Seebach has not met his burden of establishing a prima facie case that the Court has personal jurisdiction under Wis. Stat. § 801.05(4).Read the full opinion on CourtListener →
Section 801.05(4) requires regular, ongoing, or repetitive solicitation in Wisconsin at the time of injury; contacts tied to one transaction do not suffice.
Burow v. Miethner · filed 2021-03-16(4)
At the time of Plaintiff’s alleged injury, Defendants were not carrying on “regular, ongoing or repetitive” solicitation in Wisconsin.Read the full opinion on CourtListener →
Section 801.05(4)(a) requires regular, ongoing, or repetitive solicitation or service activity in Wisconsin; two attestation letters sent at the plaintiff’s request do not suffice.
Dental Health Products Inc v. Sunshine Cleaning General Services Inc · filed 2022-05-23(4)(a)
DHP has not established that Global engages in regular, ongoing, or repetitive solicitation in the state of Wisconsin. Therefore, this Court does not have personal jurisdiction over Global under Wis. Stat. § 801.05(4).Read the full opinion on CourtListener →
Section 801.05(4)(a) permits personal jurisdiction when either solicitation or service activities are carried out in Wisconsin on the defendant’s behalf in connection with an in-state injury caused by conduct outside Wisconsin.
Cook Logistics LLC v. Equipment Express Inc · filed 2022-07-28(4)(a)
As the court explained when it denied the motion to dismiss, the statute provides that personal jurisdiction may be established when either solicitation or service activities are carried out within this state on behalf of the defendant.Read the full opinion on CourtListener →
Section 801.05(1)(d) requires substantial and not isolated activities in Wisconsin when the action is commenced; earlier contacts alone do not establish personal jurisdiction.
Englewood Marketing Group Inc v. ONL-RBW Logistics LLC · filed 2023-04-24(1)(d)
In applying § 801.05(1)(d), a court must analyze a defendant’s contacts at the time the action is commenced, not the defendant’s contacts preceding the commencement of the action.Read the full opinion on CourtListener →
Section 801.05(4)(a) requires solicitation or service activities in Wisconsin by or attributable to the defendant; sales through bookstores and online platforms, without more, do not satisfy that requirement.
Salinger v. Lawler · filed 2025-08-27(4)(a)
Lawler’s book sold in bookstores in Wisconsin and online platforms that deliver to Wisconsin, but, without more, that does not constitute solicitation or service activities by Lawler or attributable to Lawler.Read the full opinion on CourtListener →
Section 801.05(4)(a) requires solicitation or service activities in Wisconsin by or on behalf of the defendant; calls and mailed documents that do not solicit a deposit do not satisfy the solicitation requirement.
David G. Stauffacher and John P. Stauffacher v. John A. Bennett and First Heritage Savings Credit Union · filed 1992-07-28(4)(a)
But only, so far as bears on this case, if “solicitation or service activities were carried on within this state by or on behalf of . the defendant.” Wis. Stat. § 801.05(4)(a). First Heritage carried on neither type of activity in Wisconsin. Bennett’s one or two calls, and his mailing of some documents, were not solicitations; whether they could be construed as service activities is impossible to glean from this record.Read the full opinion on CourtListener →
Section 801.05 permits personal jurisdiction based on substantial, nonisolated activities in Wisconsin and products used or consumed there in the ordinary course of trade.
Century Industries, Inc. v. Wenger Corp. · filed 1994-04-21(1)(d), (4)
Here, the evidence demonstrates that the defendants were “engaged in substantial and not isolated activities within this state,” Wis. Stat. § 801.05(l)(d), and that “[pjroducts ... serviced or manufactured by the defendants were used or consumed within this state in the ordinary course of trade.” Wis.Stat. § 801.05(4).Read the full opinion on CourtListener →
Section 801.05 requires a plaintiff to establish a basis for personal jurisdiction over a nonresident defendant under Wisconsin’s long-arm statute.
The Fresh Group Ltd v. Elkay Plastics Co Inc · filed 2023-06-09
But TFG did not submit any such evidence. Nor has it developed any argument why this court’s exercise of personal jurisdiction over Elkay comports with Wisconsin’s long-arm statute or due process. As such, the court finds that TFG has not met its burden and will grant Elkay’s motion to dismiss pursuant to Fed. R. Civ. P. 12(b)(2).Read the full opinion on CourtListener →
Section 801.05 supports personal jurisdiction when defendants engage in substantial activities in Wisconsin and their products are used there in the ordinary course of trade.
HARLEY-DAVIDSON v. Columbia Tristar Home Video · filed 1994-05-03(1)(d), (4)
Here, the evidence demonstrates that the defendants were "engaged in substantial and not isolated activities within this state," Wis. Stat. § 801.05(1)(d), and that "[p]roducts ... serviced or manufactured by the defendant[s] were used or consumed within this state in the ordinary course of trade." Wis.Stat. § 801.05(4).Read the full opinion on CourtListener →
Section 801.05(1)(d) permits personal jurisdiction based on substantial, systematic, and continuous business contacts with Wisconsin, even without physical presence in the state.
Harley-Davidson Motor Co. v. Motor Sport, Inc. · filed 1997-04-15(1)(d)
First, the evidence now before the court clearly shows that Motor Sport was engaged in substantial, systematic, and continuous activities within Wisconsin. See Wis. Stat. § 801.05(l)(d). For more than twenty years, the defendant has consistently maintained its distributorship relationship with the plaintiff through telephone, mail, and facsimile contacts with, for the most part, Harley-Davidson’s Wisconsin office. Motor Sport’s lack of physical presence in Wisconsin is not dispositive; to find that it is would be to disregard the way that most modem businesses conduct their everyday activities.Read the full opinion on CourtListener →
Section 801.05(1)(d) permits personal jurisdiction when a sustained business relationship and repeated communications with a Wisconsin resident constitute substantial, nonisolated activity in the state.
PKWare, Inc. v. Meade · filed 2000-01-07(1)(d)
While the duration of the relationship was shorter here, a six year business relationship which included numerous communications to and from Wisconsin is enough to warrant an inference that ASI benefitted from services provided in Wisconsin and could therefore be required as a quid pro quo to submit to the jurisdiction of Wisconsin courts. ... Because I find that defendants are subject to this court’s jurisdiction based on § 801.05(l)(d) it is unnecessary to analyze whether jurisdiction is also proper under the other subsections of the statute.Read the full opinion on CourtListener →
Section 801.05(4)(a) does not require the defendant’s additional Wisconsin contact to be a solicitation directed at the plaintiffs.
Schimpf v. Gerald, Inc. · filed 1998-04-24(4)(a)
Wisconsin law controls this issue and it does not require the additional contact for purposes of the long-arm statute to be made to the plaintiffs themselves.Read the full opinion on CourtListener →
Section 801.05(1)(d) permits personal jurisdiction when a defendant’s Wisconsin activities are substantial and not isolated at the time the action begins; extensive contract communications and meetings can satisfy that requirement.
Miller Brewing Co. v. Acme Process Equipment Co. · filed 1977-10-20(1)(d)
On this basis as well, therefore, I conclude that personal jurisdiction may appropriately be exercised as to Acme under Wis.Stat. § 801.05(1)(d).Read the full opinion on CourtListener →
Section 801.05(1)(d) permits personal jurisdiction when a defendant’s Wisconsin activities are substantial and not isolated.
Harley-Davidson Motor Co. v. Strada · filed 1978-04-25(1)(d)
Thus, applying the Nagel analysis to the circumstances of this case, the Court finds that defendant R & M Engineering’s contacts with the State of Wisconsin are substantial and not isolated, and are therefore sufficient to bring the defendant within the scope of Wis.Stat. § 801.05(l)(d).Read the full opinion on CourtListener →
Section 801.05(1)(d) requires a defendant’s Wisconsin activities to be continuous and systematic; mere contacts with the state are insufficient.
Capitol Indemnity Corp. v. Certain Lloyds Underwriters And/or London Companies · filed 1980-04-02(1)(d)
In order to base personal jurisdiction on section 801.05(l)(d), a court must find more than just contacts between the defendant and the forum. Rather, the activity of defendant must have been both “continuous and systematic.”Read the full opinion on CourtListener →
Section 801.05(1)(d) requires substantial and not isolated activities in Wisconsin to support personal jurisdiction.
International Communications, Inc. v. Rates Technology, Inc. · filed 1988-01-28(1)(d)
An analysis of the factors shows that the contacts of Rates and Weinberger with Wisconsin fail to meet the “substantial and not isolated” prerequisites of § 801.05(l)(d), nor do they meet the requirements of due process to support jurisdiction in this case.Read the full opinion on CourtListener →
Section 801.05(1)(d) permits personal jurisdiction when a defendant’s continuing business relationship with a Wisconsin resident amounts to substantial and not isolated activity in the state.
Johnson Worldwide Associates, Inc. v. Brunton Co. · filed 1998-05-08(1)(d)
Because the requirements of section 801.05(l)(d) are satisfied, analysis of the other provisions is unnecessary.Read the full opinion on CourtListener →
Section 801.05(1)(d) subjects a nonresident distributor to personal jurisdiction when its ongoing business with a Wisconsin manufacturer and substantial sales to Wisconsin customers are substantial and not isolated activities in the state.
Generac Corp. v. Omni Energy Systems, Inc. · filed 1998-09-30(1)(d)
Under Wis.Stat. § 801.05(1)(d), a non-resident defendant is subject to jurisdiction in this state if, at the time the action is commenced, the defendant “[i]s engaged in substantial and not isolated activities within this state, whether such activities are wholly interstate, intrastate, or otherwise.” ... These are not insubstantial or isolated activities. These are substantial, continuous and systematic contacts with the State of Wisconsin initiated by Omni in an effort to make money from Wisconsin entities.Read the full opinion on CourtListener →
Section 801.05(4)(a) does not reach federal supervisors merely because they supervised agents investigating activities in Wisconsin.
Kaufmann v. United States · filed 1993-12-22(4)(a)
In my opinion, this does not amount to “[solicitation or service activities ... by or on behalf of’ them in Wisconsin such that the Wisconsin long-arm statute reaches them and subjects them to personal jurisdiction in Wisconsin.Read the full opinion on CourtListener →
Section 801.05(1)(d) requires substantial activities in Wisconsin to establish a defendant’s presence there; isolated activities are insufficient.
Engineering Sales Co. v. Techni-Cast Corp. · filed 1978-01-20(1)(d)
My appraisal of the plaintiff’s contentions as to personal jurisdiction leads me to the conclusion that this defendant engaged in only isolated activities and not substantial activities within Wisconsin and therefore was not “present” in this state pursuant to § 801.05(l)(d), Wis.Stats.Read the full opinion on CourtListener →
Section 801.05(1)(d) permits personal jurisdiction over a nonresident individual whose Wisconsin real estate and partnership activities are substantial and not isolated.
Schroeder v. Raich · filed 1979-05-30(1)(d)
On the basis of the record, we hold that at the commencement of this action Raich was “engaged in substantial and not isolated activities within” Wisconsin, within the meaning of sec. 801.05(1) (d), Stats.Read the full opinion on CourtListener →
Section 801.05(1)(d) permits personal jurisdiction over a nonresident parent when visits with children in Wisconsin constitute substantial and not isolated activities.
MARRIAGE OF McCARTHY v. McCarthy · filed 1988-09-14(1)(d)
Because John’s visitations with his children in Wisconsin constitute "substantial and not isolated activities” within the meaning of sec. 801.05(l)(d), Stats., we reverse the order of dismissal and direct the trial court to consider the merits of Mary Ann’s motion.Read the full opinion on CourtListener →
Section 801.05(1)(d) does not confer personal jurisdiction based on infrequent use of Wisconsin roads that is unrelated to the lawsuit.
Ladwig v. Truck Insurance Exchange · filed 1980-10-17(1)(d)
I find that the infrequent use of Wisconsin roads by Garrett does not constitute the “continuous and systematic” activity necessary to confer jurisdiction under § 801.05(l)(d).Read the full opinion on CourtListener →
Section 801.05(1)(d) permits personal jurisdiction based on a defendant’s substantial and continuing contacts with Wisconsin, including ongoing contracts and purchases from Wisconsin companies.
Jadair, Inc. v. Van Lott, Inc. · filed 1981-04-28(1)(d)
In applying this subsection a court looks to the defendant’s general contacts with the forum state and not merely to its contacts arising out of the specific transaction at issue. ... Van Lott’s contacts, in contrast, are documented in the record and they are substantial and not isolated. ... Because I find statutory jurisdiction under § 801.05(l)(d), Wis.Stats., I need not consider the applicability of § 801.05(5)(b) and (d).Read the full opinion on CourtListener →
Section 801.05 permits personal jurisdiction based on substantial, nonisolated Wisconsin activities and on specified promises concerning services performed or goods shipped from Wisconsin.
Voorlas Manufacturing Co. v. Mars Signal Light Co. · filed 1979-12-17(1)(d), (5)(a), (5)(d)
In view of the defendant’s numerous contacts with this state, personal jurisdiction over it is provided by § 801.05(l)(d), Wis. Stats., which extends personal jurisdiction over defendants “engaged in substantial and not isolated activities within this state, whether such activities are wholly interstate, intrastate, or otherwise.” Jurisdiction is also provided by § 801.05(5)(a) and (d) which extend jurisdiction over defendants in actions arising out of promises to pay for services to be performed in this state or relating to goods shipped from Wisconsin by the plaintiff on the defendant’s order.Read the full opinion on CourtListener →
Section 801.05(1)(d) requires substantially greater Wisconsin contacts to establish jurisdiction when a nonresident plaintiff’s claim has no connection to Wisconsin than when the plaintiff is a resident or the claim is connected to the state.
Vermont Yogurt Co. v. Blanke Baer Fruit & Flavor Co. · filed 1982-05-05(1)(d)
The question, then, is whether sec. 801.05(1) (d), Stats., should be interpreted to require more substantial “doing business” contacts within this state when jurisdiction is invoked by a nonresident, whose cause of action has no cónnection with this state, than when it is invoked by a resident or by one whose cause of action arose in Wisconsin. We conclude that both the statutory and the due process analysis dictate an affirmative answer to that question.Read the full opinion on CourtListener →
Section 801.05(4)'s solicitation requirement is not satisfied by mailing stock certificates or a dissolution notice when the sender did not anticipate a financial benefit from the mailings.
Pavlic v. Woodrum · filed 1992-04-22(4)
The only contacts Timothy had with Wisconsin were two contacts through the mail: one mailing of the stock certificates and one mailing of the notice of the corporation's dissolution. These contacts were not solicitation within the meaning of sec. 801.05(4), Stats.Read the full opinion on CourtListener →
Section 801.05(4)(a) requires regular, ongoing or repetitive service activities in Wisconsin; two isolated visits do not satisfy that requirement.
Housing Horizons, LLC v. Alexander Co., Inc. · filed 1999-12-09(4)(a)
Our reading of the statutory language, Foster's Revision Notes and the judicial opinions which have touched on the meaning of the term lead us to conclude that the legislature contemplated something beyond isolated and fleeting contacts with our state when it enacted the "service activities" requirement of § 801.05(4)(a). The term requires that a defendant (or its representative) be engaged in some type of regular, ongoing or repetitive activities in Wisconsin.Read the full opinion on CourtListener →
Contracts for goods and services
Section 801.05(5)(d) authorizes personal jurisdiction over an action relating to goods shipped from Wisconsin by the plaintiff to the defendant on the defendant’s order or direction.
Mamco Corp. v. Max Buchanan Co. · filed 1992-05-26(5)(d)
The Wisconsin long-arm statute authorizes the exercise of jurisdiction here, because the action “[rjelates to goods ... shipped from this state by the plaintiff to the defendant on the defendant’s order or direction_” Wis.Stat. § 801.05(5)(d); see also Sub-Zero Freezer Co. v. R.J. Clarkson Co., 159 Wis.2d 230, 234 (Ct.App.1990).Read the full opinion on CourtListener →
Section 801.05(5)(b) does not confer personal jurisdiction based on a brief Wisconsin service visit incidental to a lengthy consulting relationship centered abroad.
Kinetic Co., Inc. v. BDO EOS SVETOVANJE, DOO · filed 2005-03-18(5)(b)
Though Simac participated in a business meeting while in Wisconsin (thus, providing services to Kinetic), he was in Wisconsin overnight and the meeting comprised only three and one-half hours of a two and one-half year relationship. Based on these circumstances, the Court concludes that Kinetic has not met its burden of establishing that the Court has personal jurisdiction over EOS under Wis. Stat. § 801.05(5)(b).Read the full opinion on CourtListener →
Section 801.05(5)(b) permits personal jurisdiction over a dispute arising from services that a defendant authorizes a Wisconsin plaintiff to perform on its behalf, including patent prosecution and maintenance duties under a license.
Eragen Biosciences, Inc. v. Nucleic Acids Licensing, LLC · filed 2006-08-08(5)(b)
When a defendant authorizes a Wisconsin plaintiff to perform services on its behalf, § 801.05(5)(b) gives a court personal jurisdiction over any conflict that arises out of the performance or non-performance of those services. Although the dispute in this case involves royalty payments primarily, the parties disagree about whether plaintiff performed other obligations under the licensing agreement, including making required maintenance payments. Because the terms of the agreement require plaintiff to provide ongoing services to defendant Nucleic Acids Licensing LLC, by prosecuting its patents, paying maintenance fees for the licensed patents and potentially bringing suit against alleged infringers of the licensed patents, the agreement authorizes plaintiff to perform services on defendant’s behalf. Consequently, the Wisconsin long arm statute reaches defendant Nucleic Acids Licensing LLC under § 801.05(5)(b).Read the full opinion on CourtListener →
Section 801.05(5)(b) permits personal jurisdiction when the plaintiff performs services for the defendant in Wisconsin and the defendant authorizes or ratifies that work.
Stayart v. Hance · filed 2007-08-01(5)(b)
We conclude that Stayart has met his burden of showing that he performed services in Wisconsin for Hance and that Hance authorized or ratified those actions. That satisfies Wis. Stat. § 801.05(5)(b).Read the full opinion on CourtListener →
Section 801.05(5)(b) permits personal jurisdiction over an action arising from services the plaintiff performed for the defendant in Wisconsin with the defendant’s authorization or ratification.
Total Administrative Services Corp. v. Pipe Fitters Union Local No. 120 Insurance Fund · filed 2015-09-17(5)(b)
Construing the facts in TASC’s favor, the court is satisfied that this case.'arises out of'services that TASC provided for the Fund in Wisconsin, and with the Fund’s authorization or ratification.Read the full opinion on CourtListener →
Section 801.05(10)(a) does not confer personal jurisdiction over a nonresident reinsurer that made no promise to insure the plaintiff, even if the original insurers made such promises.
Employers Ins. Co. of Wausau v. EQUITAS HOLDINGS · filed 2006-09-12(10)(a)
Defendants made no promise to insure plaintiff; therefore, it would be incorrect to assert personal jurisdiction over the Equitas defendants under Wis. Stat. § 801.05(10)(a).Read the full opinion on CourtListener →
Section 801.05(5)(d) reaches an action concerning goods a nonresident defendant requested to be shipped from Wisconsin.
Kuhn Knight, Inc. v. VMC Enterprises, Inc. · filed 2006-12-07(5)(d)
When a defendant requests goods to be shipped to it from Wisconsin, Wis. Stat. § 801.05(5)(d) gives a court personal jurisdiction over any action relating to those goods. In this case, it is undisputed that defendants ordered a mixer from plaintiff in August 2006, and that the parties’ present dispute arises out of defendant’s alleged failure to pay for the mixer in a timely manner. Therefore, the Wisconsin long arm statute reaches defendant under § 801.05(5)(d).Read the full opinion on CourtListener →
Section 801.05(5)(d) reaches an action relating to goods or things of value shipped from Wisconsin at the defendant’s direction; the action need not concern the shipment itself.
Shared Medical Equipment Group, LLC v. Simi Valley Hospital & Healthcare Services · filed 2014-02-25(5)(d)
That section requires only that the action relate to the “goods” or “things of value” that have been shipped from Wisconsin, not to the shipment itself.Read the full opinion on CourtListener →
Section 801.05(5)(d) permits personal jurisdiction in an action seeking payment for goods shipped from Wisconsin to the defendant on its order or direction.
Cranberry Growers Cooperative v. Maxwell Food Products Pty. Ltd. · filed 2019-10-11(5)(d)
Plaintiff contends that this court has personal jurisdiction over defendant under section § 801.05(5)(d), which extends personal jurisdiction in an action which “[r]elates to goods, documents of title, or other things of value shipped from this state by the plaintiff to the defendant on the defendant’s order or direction.” Here, plaintiff seeks payment of the money defendant owes for the cranberries that plaintiff shipped from Wisconsin to defendant pursuant to the parties’ contract. Defendant effectively concedes that its contract with plaintiff brings it within the ambit of the long-arm statute. Dkt. #16 at 3. Therefore, I conclude that the statutory requirement is met and I turn to the constitutional inquiry.Read the full opinion on CourtListener →
Section 801.05(5)(d) permits personal jurisdiction when goods are shipped from Wisconsin to a third party at the defendant’s order or direction.
Johnson Litho Graphics of Eau Claire, Ltd. v. Sarver · filed 2012-09-06(5)(d)
We conclude that the meaning of the phrase "to the defendant" in Wis. Stat. § 801.05(5)(d) includes shipping goods from Wisconsin to third parties at the defendant's order or direction.Read the full opinion on CourtListener →
Section 801.05(5)(a) covers an action arising from a promise to pay for services performed in Wisconsin.
Gorokhovsky v. Stefantsova · filed 2019-07-31(5)(a)
Effectively, Stefantsova made a promise to pay Gorokhovsky for services that he would perform in Wisconsin, and this cause of action arose from that agreement. Therefore, the statute clearly encompasses Stefantsova’s conduct.Read the full opinion on CourtListener →
Section 801.05(5)(b) does not confer personal jurisdiction merely because a defendant incidentally benefits from services the plaintiff performed in Wisconsin.
IKON Transportation Services, Inc. v. Advanced Containment Systems, Inc. · filed 2020-01-27(5)(b)
The court concludes that providing some incidental benefit to an out-of-state defendant isn’t sufficient to show that a plaintiff performed services for that defendant under § 801.05(5)(b).Read the full opinion on CourtListener →
Section 801.05(4)(a), (5)(a), and (5)(b) permit personal jurisdiction over an out-of-state client who authorized legal services in Wisconsin, promised to pay for those services, and allegedly caused injury there by failing to pay.
Jerome R Kerkman SC v. D'Amico · filed 2021-09-28(4)(a), (5)(a), (5)(b)
Because the plaintiff’s claims arise from an agreement the defendant voluntarily signed, agreeing to retain a Wisconsin law firm and Wisconsin lawyers to perform legal services for her, some of which would necessarily be performed in the state of Wisconsin, and because the plaintiff has alleged a breach of that contract which resulted in injury in the state of Wisconsin, the plaintiff has carried the burden of showing that this court has personal jurisdiction under the Wisconsin long-arm statute and under the principles of due process.Read the full opinion on CourtListener →
Section 801.05(5)(b) permits personal jurisdiction when an action arises from services the defendant performed for the plaintiff in Wisconsin; the plaintiff need not allege injury from those services.
Hribar Transport LLC v. Slegers · filed 2021-09-29(5)(b)
Contrary to the defendant’s assertion, §801.05(5)(b) does not require the plaintiff to allege that it was injured by services the defendant performed for the plaintiff in Wisconsin.Read the full opinion on CourtListener →
Section 801.05(5) permits personal jurisdiction over contract claims involving goods shipped to or from Wisconsin when the alleged distribution arrangement supports an inference that products were shipped to Wisconsin.
Track, Inc. v. Swenson Spreader, LLC · filed 2023-03-31(5)
As for Wisconsin’s long-arm state, Track’s claims would fall within the scope of Wis. Stat. § 801.05(5), which provides jurisdiction in actions arising from contracts for goods shipped to or from Wisconsin.Read the full opinion on CourtListener →
Section 801.05(5)(c) confers specific personal jurisdiction when the plaintiff makes a prima facie showing that its claims arise from the defendant’s manufacture and shipment of goods from Wisconsin.
RCBA Nutraceuticals LLC v. Proampac Holdings Inc · filed 2023-06-29(5)(c)
Because RCBA’s contract and tort claims arise in part out of these allegations, the court finds that RCBA has made a prima facie showing that § 801.05(5)(c) confers specific personal jurisdiction over ProAmpac.Read the full opinion on CourtListener →
Meeting § 801.05(5)’s contract-related requirements satisfies the plaintiff’s initial statutory burden and raises a presumption that personal jurisdiction complies with due process.
Uni-Bond, Ltd. v. Schultz · filed 1985-05-02(5)
Based on this preliminary analysis, the Court concludes that the plaintiff has met its initial burden of establishing the Court’s personal jurisdiction over the defendant under Wisconsin’s long-arm statute, Wis.Stat. § 801.05(5) (1977). In turn, since § 801.05 was drafted as a codification of those minimum contacts sufficient to comport with a nonresident party’s right to due process under the Fourteenth Amendment to the United States Constitution, compliance with the statute raises a presumption of compliance with the minimal requirements of due process.Read the full opinion on CourtListener →
Section 801.05(5)(a) permits personal jurisdiction based on a nonresident buyer’s promise to pay for goods manufactured by the seller in Wisconsin, subject to due process.
Walworth Woodcraft, Inc. v. Metropolitan Consolidated Industries, Inc. · filed 1986-06-23(5)(a)
Because the case at bar arises out of Metropolitan’s promise to pay for the display racks manufactured by the plaintiff in Wisconsin, § 801.05(5)(a) tends to provide a basis for applying the state’s long-arm jurisdiction over Metropolitan. ... In sum, the court finds that this is a clear case in which the exercise of jurisdiction over a nonresident defendant comports with both due process and the Wisconsin long-arm statute.Read the full opinion on CourtListener →
Section 801.05(5)(c) authorizes personal jurisdiction over parties that contract to ship goods into Wisconsin.
United Rope Distributors, Incorporated v. Seatriumph Marine Corporation · filed 1991-05-09(5)(c)
Logically, the next question is whether Wis.Stat. § 801.05(5)(c), adopted by Fed.R.Civ.P. 4(e), is such a law. It creates personal jurisdiction over parties that contract to ship goods into the state, which describes this case.Read the full opinion on CourtListener →
Section 801.05(5)(a) requires a contract to contemplate a substantial connection with Wisconsin; insurance coverage provided in another state did not satisfy that requirement.
Federated Rural Electric Insurance Corp. v. Inland Power and Light Co. · filed 1994-02-25(5)(a)
In deciding this matter, we agree with the district court in its finding that, under the facts of this case, the contract provision of the long-arm statute, § 801.05(5), does not subject Defendant to personal jurisdiction in Wisconsin. ... Because Defendant engaged in business in the Pacific Northwest only, Plaintiff performed all of these services in the Pacific Northwest rather than in its home office of Wisconsin.Read the full opinion on CourtListener →
Section 801.05(5)(e) permits personal jurisdiction in an action involving goods the plaintiff actually receives in Wisconsin from the defendant, regardless of where the goods were delivered to a carrier.
Mid-America Tablewares, Inc. v. Mogi Trading Co. · filed 1996-11-22(5)(e)
By its plain language, this section applies to actions involving goods actually received by the plaintiff in this state from the defendant regardless of where delivery to a carrier took place.Read the full opinion on CourtListener →
Section 801.05(5)(d) permits personal jurisdiction over an action arising from goods shipped from Wisconsin to a defendant on the defendant’s order or direction.
Diemel v. Tolley · filed 2022-06-08(5)(d)
Section 801.05(5)(d) of the Wisconsin Statutes provides that the state’s courts have jurisdiction over the defendant in any action which “relates to goods, documents of title, or other things of value shipped from this state by the plaintiff to the defendant on the defendant’s order or direction.” Diemel’s action against Tolley arises out of Diemel’s shipment of goods (cattle) from this state to Mr. Tolley on Mr. Tolley’s order or direction.Read the full opinion on CourtListener →
Section 801.05(5)(d) covers an action involving goods shipped from Wisconsin on the defendant’s order, subject to due process limits on personal jurisdiction.
Lakeside Bridge & Steel Co. v. Mountain State Construction Co., Inc. · filed 1979-06-08(5)(d)
Subsection (d), on its face, covers this case, but is subject to the due process limitation, as noted earlier.Read the full opinion on CourtListener →
Section 801.05(5)(d) covers stock certificates shipped from Wisconsin at the defendants’ direction, even when a California escrow company handles delivery.
Mid-States Mortgage Corp. v. Louie · filed 1993-12-06(5)(d)
The Court incorporates the Magistrate’s reasoning and analysis relative thereto and finds *872that the exercise of personal jurisdiction is warranted pursuant to Wis.Stat. § 801.-05(5)(d). ... The stock certificates constitute “documents of title or other things of value” which were shipped to the defendants from Wisconsin at their order or direction. The fact a California escrow company was utilized as a conduit to effect the delivery of the stock certificates *875does not alter this Court’s conclusion.Read the full opinion on CourtListener →
Section 801.05(5)(a) and (b) authorize personal jurisdiction in cases involving services performed in Wisconsin for a defendant, subject to due process limits.
JJ & J. Foundation Co., Inc. v. Tommy Moore, Inc. · filed 1986-08-01(5)(a) and (b)
The court notes that the Wisconsin long-arm statute authorizes the exercise of personal jurisdiction over defendants in cases such as the present case, subject, of course, to Due Process limitations.Read the full opinion on CourtListener →
Section 801.05(5) reaches a service contract when some services were contemplated or authorized to be performed in Wisconsin; substantial performance there is unnecessary.
Daniel J. Hartwig Associates, Inc. v. Kanner · filed 1990-09-19(5)
The long-arm statute requires only that some services were contemplated to be or actually were performed in Wisconsin.Read the full opinion on CourtListener →
Section 801.05(5)(e) authorizes service on a seller for breach of contract and warranty claims when the plaintiff actually receives the seller’s goods in Wisconsin.
Schartner v. Northwest Intern. Equipment Co., Inc. · filed 1988-09-14(5)(e)
However, it is clear that the plaintiff actually received the goods in the state from the defendant, so subsection 801.05(5)(e) authorizes service of process on the defendant for the breach of contract and breach of warranty claims.Read the full opinion on CourtListener →
Section 801.05(5)(a) and (d) permits personal jurisdiction when a defendant promises to pay for services performed in Wisconsin or an action relates to goods shipped from Wisconsin at the defendant’s direction.
M.C.I., Inc. v. Elbin · filed 1988-08-04(5)(a), (d)
The affidavit filed by MCI in opposition to Elbin’s motion for summary judgment states that Elbin paid MCI to purchase or manufacture certain materials in Wisconsin for use at the Illinois construction site, and that the action related to goods shipped to Elbin at his order. Those facts are not contravened in Elbin’s affidavits and, taken together, they are sufficient to support the court’s conclusion that personal jurisdiction exists under secs. 801.05(5)(a) and (d), Stats.Read the full opinion on CourtListener →
Section 801.05(5)(d) covers an action alleging breach of a settlement agreement resolving disputes over goods shipped from Wisconsin on the defendant's order.
Sub-Zero Freezer Co. v. R.J. Clarkson Co. · filed 1990-11-15(5)(d)
We reject Clarkson's contention that this action does not relate to "goods" but rather to its settlement agreement with Sub-Zero. The agreement settled claims arising from sales contracts. Those contracts involved goods shipped or to be shipped from Wisconsin and ordered by Clarkson. An action alleging breach of an agreement settling contract disputes concerning goods "relates" to those same goods.Read the full opinion on CourtListener →
Section 801.05(5)(d) provides personal jurisdiction over an out-of-state buyer in an action involving goods shipped from Wisconsin on the buyer's direct order.
Riggs Marine Service, Inc. v. McCann · filed 1991-02-13(5)(d)
The transaction between Riggs and McCann involved the sale and shipping of four outboard motors by Riggs, in Wisconsin, to McCann, in Ohio, on McCann's direct order. It is precisely the type of business transaction covered by sec. 801.05(5) (d).Read the full opinion on CourtListener →
Section 801.05(5)(a) and (b) confer jurisdiction over arrangements for services performed in Wisconsin by one party for the other.
Landreman v. Martin · filed 1995-02-28(5)(a), (b)
These subsections contemplate arrangements for the performance of services within this state by either party for the other.Read the full opinion on CourtListener →
Section 801.05(5)(b) permits personal jurisdiction when the plaintiff performs services for the defendant in Wisconsin and the defendant authorizes or ratifies that performance.
Regal Ware, Inc. v. TSCO CORP. · filed 1996-12-18(5)(b)
Section 801.05(5)(b), Stats., plainly encompasses the types of activities in which Regal Ware and TSCO engaged. The statute requires only that services be performed for the defendant by the plaintiff within the state and that such performance is "authorized or ratified" by the defendant.Read the full opinion on CourtListener →
Section 801.05(5)(b) permits personal jurisdiction when an action arises from services performed in Wisconsin for a defendant with the defendant’s authorization, subject to due process.
Brown v. LaChance · filed 1991-09-17(5)(b)
Under sec. 801.05(5)(b), Stats., Wisconsin has jurisdiction over Rudnick where the action arises out of services LaChance and Smith performed within this state for and authorized by Rudnick.Read the full opinion on CourtListener →
Section 801.05(5)(c) gives Wisconsin courts personal jurisdiction over an action arising from a defendant's promise to deliver goods in Wisconsin.
Precision Erecting, Inc. v. M&I Marshall & Ilsley Bank, G.A.P., Inc. · filed 1998-12-16(5)(c)
We agree with the trial court that this paragraph gives the Waukesha County Circuit Court jurisdiction over Nambe. It promised to and did deliver the muller to AFW in Waukesha, Wisconsin.Read the full opinion on CourtListener →
Corporate and agency contacts
Section 801.05 permits personal jurisdiction over an individual whose Wisconsin contacts were made on behalf of a corporation; Wisconsin does not apply the fiduciary shield doctrine.
Norkol/Fibercore, Inc. v. Gubb · filed 2003-08-25
For the foregoing reasons, I do not believe that Wisconsin would embrace the fiduciary shield doctrine. Thus, the fact that Gubb’s contacts with Wisconsin occurred while he was acting on behalf of Sterling is not a bar to the exercise of jurisdiction over him as an individual by this court.Read the full opinion on CourtListener →
Section 801.05(8) permits jurisdiction over a domestic limited liability company’s manager when a breach of contract claim arises from the manager’s conduct or the company’s activities while the manager held office.
Taurus IP, LLC v. Daimlerchrysler Corp. · filed 2007-10-15(8)
Defendants’ claim for breach of contract “arises out” of Spangenberg’s conduct and plaintiffs activity because of the activities Spangenberg took while managing member of domestic limited liability company plaintiff, including directing it to file a lawsuit that allegedly resulted in Orion IP’s breach of a Licensing Agreement between Orion IP Delaware and defendant DaimlerChrysler. Therefore, subsection (8) authorizes jurisdiction over Spangenberg.Read the full opinion on CourtListener →
Section 801.05(8) treats a manager of a Wisconsin corporation as consenting to Wisconsin personal jurisdiction over an action arising from that role, even with only minimum contacts with the state.
Kubin-Nicholson Corp. v. Gillon · filed 2007-12-13(8)
Section 801.05(8) treats a manager of a Wisconsin corporation as having consented to the state’s jurisdiction.Read the full opinion on CourtListener →
Section 801.05(1)(c) can reach persons who controlled a Wisconsin LLC as their alter ego, if evidence establishes that control.
Rual Trade Ltd. v. Viva Trade LLC · filed 2008-04-28(1)(c)
If plaintiff discovers evidence that the Lithuanian defendants controlled Viva in 2003 and 2004, then such defendants would fall within Wisconsin’s long-arm statute.Read the full opinion on CourtListener →
Section 801.05(1)(d) permits general jurisdiction over a nonresident parent based on its subsidiary’s Wisconsin activities only when the parent’s control justifies disregarding their separate corporate identities.
Rasmussen v. General Motors Corp. · filed 2011-07-01(1)(d)
We conclude that even assuming arguendo that Nissan North America were the agent of Nissan Japan, absent control by Nissan Japan sufficient to cause us to disregard the separate corporate identities of Nissan Japan and Nissan North America, the activities of the subsidiary corporation are insufficient to subject its nonresident parent corporation to general personal jurisdiction under Wis. Stat. § 801.05(l)(d).Read the full opinion on CourtListener →
Section 801.05(8) permits personal jurisdiction over a domestic corporation’s vice president when the plaintiff makes a prima facie showing that the vice president had officer responsibilities and the claims arise from his conduct in that role.
Johnson Financial Group Inc v. McGill · filed 2021-05-25(8)
The Court finds that McGill falls within the coverage of section 801.05(8) of Wisconsin’s long-arm statute.Read the full opinion on CourtListener →
Section 801.05(8) permits personal jurisdiction over officers and directors of Wisconsin corporations in actions relating to their conduct in those roles, even when their other Wisconsin contacts are minimal.
Stearn v. Malloy · filed 1981-02-19(8)
Section 801.05(8) furthers that goal by providing personal jurisdiction over the officers and directors of Wisconsin corporations in actions relating to their conduct in such positions. This does not offend the due process standards of International Shoe Co. v. Washington, 326 U.S. 310, 66 S.Ct. 154, 90 L.Ed. 95 (1945).Read the full opinion on CourtListener →
Section 801.05(1)(d) permits jurisdiction over a nonresident parent when its relationship with a subsidiary is accompanied by the subsidiary’s substantial and systematic activities in Wisconsin.
Brunswick Corp. v. Suzuki Motor Co., Ltd. · filed 1983-11-30(1)(d)
The Court holds, on the contrary, that the totality of the parents’ contacts with Wisconsin satisfies the requirements of the state long-arm statute. Although the mere fact of a parent-subsidiary relationship alone will not support jurisdiction over the nonresident parent, that contact with the forum in conjunction with substantial and systematic activities of the subsidiary in the forum state will suffice.Read the full opinion on CourtListener →
Section 801.05(1)(d) permits personal jurisdiction over a parent corporation when its subsidiary conducts substantial and systematic activities in Wisconsin.
Hayeland v. Jaques · filed 1994-03-29(1)(d)
Here, there is no dispute that Universal, through Faucets (which is not a separate entity, but simply a division within Universal), carries on “substantial and systematic activities” in Wisconsin. These activities, in conjunction with the parent-subsidiary relationship, satisfy long-arm jurisdiction over Nortek.Read the full opinion on CourtListener →
Section 801.05(4)(a) permits jurisdiction based on in-state activity on behalf of a nonresident defendant only when an agent connects that defendant to Wisconsin.
Insolia v. Philip Morris, Inc. · filed 1998-12-14(4)(a)
As already explained, subsection 4(a) of the statute applies only to the extent that a nonresident defendant has contacts with Wisconsin through the actions of an agent.Read the full opinion on CourtListener →
Section 801.05 permits personal jurisdiction over an individual who conducts business in Wisconsin for his own benefit as well as for a corporation; the fiduciary-shield doctrine does not protect those personal dealings.
Hardin Roller Corporation v. Universal Printing MacHinery Inc., and Joseph Yukich · filed 2001-01-03
One of the doctrine’s conditions is that the person’s business in the state be solely as a fiduciary of another person, who is liable as a principal. Yukich, however, appeared in Wisconsin both as Universal’s agent and as principal of his own proprietorship.Read the full opinion on CourtListener →
Personal jurisdiction for return or accounting of assets
Section 801.05(6)(c) permits personal jurisdiction over a claim to return or account for assets that were in Wisconsin when the defendant acquired control, regardless of how the assets were later transferred to another state.
Norton v. Bridges · filed 1983-07-15(6)(c)
Because the settlor was a Wisconsin resident, the trustee’s control over the assets necessarily originated when the assets were still in Wisconsin, at the time the trust was created. The applicability of this statutory section is unaffected by whether Page forwarded the assets to Bridges in Illinois or whether Bridges came to Wisconsin to take possession of them, a factual issue that is unclear from the record.Read the full opinion on CourtListener →
Section 801.05(6)(c) permits personal jurisdiction over a claim to recover a loan that the plaintiff arranged from its Wisconsin offices and the defendant accepted.
Topcon Agric. Ams., LLC v. Cote AG Techs., LLC · filed 2019-06-12(6)(c)
Topcon contends that this court has personal jurisdiction over Cote Ag under section 801.05(6)(c), which confers jurisdiction over claims seeking that "the defendant return, restore, or account to the plaintiff for any asset or thing of value which was within this state at the time the defendant acquired possession or control over it." Here, Topcon seeks repayment of the money it lent Cote Ag-a loan that Topcon arranged from its offices in Wisconsin. Cote Ag effectively concedes that its acceptance of this money brings it within the ambit of the long-arm statute. ... So the court concludes that the statutory requirement is met and turns to the constitutional inquiry.Read the full opinion on CourtListener →
Product distribution and processing
Section 801.05(4)(b) reaches a nonresident manufacturer when products it made outside Wisconsin are purchased and used in Wisconsin in the ordinary course of trade, including as components of other products.
LG Electronics, Inc. v. Quanta Computer Inc. · filed 2007-11-05(4)(b)
This requirement is satisfied by the purchase of defendant Quanta Storage Inc.’s DVD drives in Wisconsin by plaintiffs counsel, and the reasonable inference drawn therefrom that other consumers bought and used notebook computers containing defendant’s DVD drives in Wisconsin. Because plaintiff has shown that Wisconsin consumers can purchase and likely have purchased and used notebook computers containing defendant’s allegedly infringing DVD drives, I find that the Wisconsin long-arm statute reaches defendant Quanta Storage Inc. under 801.05(4)(b).Read the full opinion on CourtListener →
Section 801.05(4)(b) permits specific jurisdiction when an alleged injury in Wisconsin arises from acts outside the state and the defendant’s products were used or consumed in Wisconsin in the ordinary course of trade.
Engineered Products & Services, Inc. v. Echo Engineering & Production Supplies, Inc. · filed 2009-10-20(4)(b)
Plaintiff establishes the elements of personal jurisdiction required by Wis. Stat. § 801.05(4)(b).Read the full opinion on CourtListener →
Section 801.05(4)(b) treats an article published online as processed for purposes of jurisdiction over a foreign act causing injury in Wisconsin.
Salfinger v. Fairfax Media Ltd. · filed 2016-01-20(4)(b)
We therefore agree with Salfinger that an article published online is "processed" within the meaning of Wis. Stat. § 801.05(4)(b).Read the full opinion on CourtListener →
Section 801.05(4)(b) permits personal jurisdiction based on allegedly defamatory online articles that qualify as processed products used or consumed in Wisconsin, subject to due process.
Fredin, Brock v. Klasfeld, Adam · filed 2025-03-24(4)(b)
But in Salfinger, the Wisconsin Court of Appeals concluded that an allegedly defamatory article published online by the Sydney (Australia) Morning Herald did authorize jurisdiction under § 801.05(4). ... Given the liberal constriction that I must give § 801.05, I conclude that the articles here meet the requirements of Wisconsin’s long-arm statute.Read the full opinion on CourtListener →
Section 801.05(4)(b) includes loading and securing goods for shipment within “processing”; physical transformation of the goods is not required.
Kopke v. A. Hartrodt S.R.L. · filed 2001-07-10(4)(b)
Accordingly, we adopt that broad definition here. As a result, we agree with Kopke that L'Arciere engaged in processing pursuant to Wis. Stat. § 801.05(4) and affirm this conclusion by the circuit court.Read the full opinion on CourtListener →
Section 801.05(4)(b) treats a distributor’s purchase and sale of goods in the normal course of distribution as processing those goods.
Nelson ex rel. Carson v. Park Industries, Inc. · filed 1983-09-13(4)(b)
Under such a liberal construction, we conclude that the word “processed” should be interpreted to include a distributor’s purchase and sale of goods in the normal course of the distribution of those goods.Read the full opinion on CourtListener →
Section 801.05(4)(b)’s requirement that a defendant’s products be used in Wisconsin in the ordinary course of trade may be established by reasonable inference from the evidence.
Stevens v. White Motor Corp. · filed 1977-03-29(4)(b)
Findings of the facts requisite to jurisdiction under Wisconsin’s long-arm statute may properly be made, as they were here, by reasonable inference from facts proven in the record.Read the full opinion on CourtListener →
Nonresident defendants and minimum contacts
Section 801.05(1) supplies grounds for personal jurisdiction based on a defendant’s presence in Wisconsin when served, domicile there, or substantial activities there when the action begins.
Montalvo v. U.S. Title & Closing Services, LLC · filed 2012-12-04(1)
No grounds for personal jurisdiction over Montalvo under Wis. Stat. § 801.05 are apparent from the record.Read the full opinion on CourtListener →
Section 801.05 reaches as far as due process permits, so the personal-jurisdiction inquiry generally collapses into one step.
Rougeau, Lucas v. Ahlstrom Rhinelander, LLC · filed 2025-06-04
Since the Wisconsin long-arm statute, Wis. Stat. § 801.05, “is intended to reach to the fullest extent allowed under the due process clause,” this inquiry generally collapses into one step.Read the full opinion on CourtListener →
Section 801.05 permits personal jurisdiction to the fullest extent allowed by due process.
Neterval-Quiel v. SRL · filed 2022-09-12
“Wisconsin's long-arm statute, Wis. Stat. § 801.05, has been interpreted to confer jurisdiction ‘to the fullest extent allowed under the due process clause.’” Id. at 678 (quoting Daniel J. Hartwig Assocs., Inc. v. Kanner, 913 F.2d 1213, 1217 (7th Cir. 1990)). That means, so long as this Court’s exercise of personal jurisdiction would comport with the Fourteenth Amendment’s Due Process clause, jurisdiction is properly established.Read the full opinion on CourtListener →
Section 801.05 permits Wisconsin courts to exercise personal jurisdiction to the fullest extent allowed by due process.
Johnson v. Allianz Global Risks US Insurance Company · filed 2025-05-01
In Wisconsin, personal jurisdiction is governed by Wisconsin’s long-arm statute, Wis. Stat. § 801.05, which has been interpreted “to confer jurisdiction ‘to the fullest extent allowed under the due process clause.’” Id. at 678 (quoting Daniel J. Hartwig Assocs., Inc. v. Kanner, 913 F.2d 1213, 1217 (7th Cir. 1990)).Read the full opinion on CourtListener →
Satisfying § 801.05(5)'s grounds for personal jurisdiction creates a rebuttable presumption that due process requirements are met.
L.B. Sales Corp. v. Dial Manufacturing, Inc. · filed 1984-08-30(5)
If the statutory requirements are satisfied, there arises a rebuttable presumption that due process requirements have been satisfied, so that the defendant is amenable to suit. ... In this case, the requirements of Wis.Stat. § 801.05 have been met.Read the full opinion on CourtListener →
Section 801.05 requires some contact between the defendant and Wisconsin before a court may exercise personal jurisdiction under the statute.
International Placement & Recruiting v. Reagan Equipment Co. · filed 1984-09-07
Of course, these well-established standards for analysis under Wis.Stat. § 801.05 presume the existence of some contacts, however facially insubstantial, between the defendant and the forum state.Read the full opinion on CourtListener →
Section 801.05 requires sufficient minimum contacts with Wisconsin to satisfy the Fourteenth Amendment when a federal court relies on it for personal jurisdiction.
Kohler Co. v. Titon Industries, Inc. · filed 1996-12-19
In the instant case, then, where the relevant federal statute does not provide for service of process, the court’s jurisdiction is limited under Rule 4 by Wisconsin’s long-arm statute, which is itself limited by the Due Process Clause of the Fourteenth Amendment. Accordingly, I must determine whether Titon has sufficient minimum contacts with Wisconsin, rather than with the United States, in order to establish jurisdiction under Wisconsin’s long-arm statute.Read the full opinion on CourtListener →
Section 801.05 does not confer personal jurisdiction over individuals who have no contacts with Wisconsin.
Tilidetzke v. Preiss · filed 1985-07-02
Applying Wisconsin’s long-arm statute, § 801.05 Wis.Stats., the plaintiffs concede that this Court does not have personal jurisdiction over the individual defendants, who have no contacts with the State of Wisconsin. ... The Court agrees, and also finds that because this Court does not have personal jurisdiction over the individual defendants, and State Farm is not a proper party due to the no-action clause, it would be in the interests of justice to transfer this action to *278Texas where all defendants are amenable to suit.Read the full opinion on CourtListener →
Section 801.05(5) does not support personal jurisdiction when a defendant’s contacts with Wisconsin are too isolated in quantity and nature.
Management Science, Inc. v. Wilson Manufacturing Co. · filed 1978-06-16(5)
In my opinion, the defendant’s contacts with ... Wisconsin were too isolated in quantity and nature to permit the exercise of jurisdiction under the Wisconsin long arm statute.Read the full opinion on CourtListener →
Compliance with § 801.05 presumptively satisfies due process, but it does not conclusively establish personal jurisdiction.
In RE DAVANIS v. Davanis · filed 1986-06-18
While compliance with the language of sec. 801.05 is prima facie compliance with the due process requirements, the plaintiff's burden of proof is not conclusively satisfied in all cases upon a showing of compliance with the statute.Read the full opinion on CourtListener →
Section 801.05 creates a presumption of personal jurisdiction that can be overcome when exercising jurisdiction would violate due process.
Marsh v. Farm Bureau Mutual Insurance · filed 1993-08-31
However, case law makes it abundantly clear that the long-arm statute creates merely a presumption of jurisdiction that can be overcome through due process analysis.Read the full opinion on CourtListener →
Section 801.05(1)(d) requires sufficient contacts with Wisconsin to support personal jurisdiction, including when the action seeks only a divorce.
In RE MARRIAGE OF MENDEZ v. Hernandez-Mendez · filed 1997-08-27(1)(d)
Thus, the circuit court's analysis focused on the fourth ground, the "long-arm" provisions of the statute, inquiring whether Irma had sufficient minimum contacts with Wisconsin. ... In light of this record, the circuit court correctly held that Jose had not established that Irma had sufficient minimum contacts with Wisconsin.Read the full opinion on CourtListener →
Section 801.05 permits personal jurisdiction to the fullest extent allowed by due process.
Endo Ventures Unlimited v. Nexus Pharmaceuticals Inc · filed 2024-03-25
Section 801.05 “has been interpreted to confer jurisdiction ‘to the fullest extent allowed under the due process clause.’”Read the full opinion on CourtListener →
Wisconsin acts and injuries
Section 801.05(4) requires an in-state injury and does not confer jurisdiction over a patent infringement claim with no alleged infringing sale or use in Wisconsin, while § 801.05(5)(d) reaches a claim related to goods shipped from Wisconsin on the defendant’s order.
TECRE CO., INC. v. Buttonpro, Inc. · filed 2005-09-09(4), (5)(d)
Thus, plaintiff does not satisfy the requirement of § 801.05(4) that it allege an in-state injury and such section, therefore, does not confer personal jurisdiction over defendant. ... Construing § 801.05(5)(d) liberally in favor of the exercise of jurisdiction, plaintiffs allegations satisfy its requirements.Read the full opinion on CourtListener →
Section 801.05(4) permits personal jurisdiction when an out-of-state act causes injury to business reputation or goodwill in Wisconsin and the defendant conducts service activities in the state.
Pebble Beach Co. v. Northern Bay LLC · filed 2005-12-22(4)
Plaintiffs’ amended complaint alleges injuries to their business reputations and good will within the State of Wisconsin arising from defendant Tour 18’s act of sending the January 12, 2004 letter from Texas. ... Further, it is undisputed defendant Tour 18 conducted service activities within the state pursuant to its contract with defendant Northern Bay. Accordingly, defendant Tour 18 is subject to jurisdiction under Wis. Stat. § 801.05(4).Read the full opinion on CourtListener →
Section 801.05(4)(b) requires a prima facie showing of a Wisconsin injury caused by an out-of-state act and products processed, serviced, or manufactured by the defendant that were used in Wisconsin in the ordinary course of business.
Langeman Manufacturing Ltd. v. Pinnacle West Enterprises, Inc. · filed 2007-11-28(4)(b)
Thus, plaintiff must make a prima facie showing that it was injured in Wisconsin, that defendant’s act outside Wisconsin caused the injury and that defendant “processed, serviced or manufactured” products that were used in Wisconsin in the ordinary course of business.Read the full opinion on CourtListener →
Section 801.05(4)(b) permits personal jurisdiction when an out-of-state act causes injury in Wisconsin and the defendant’s processed products are consumed there in the ordinary course of trade.
Standard Process Inc. v. The Antitrend LLC · filed 2020-02-04(4)(b)
The court is satisfied that jurisdiction is proper under § 801.05(4)(b), which applies when a plaintiff suffers an injury within Wisconsin arising out of a defendant’s out-of- state act or omission if “products, materials or things processed, serviced or manufactured by the defendant were used or consumed within this state in the ordinary course of trade.”Read the full opinion on CourtListener →
Section 801.05(4) does not permit personal jurisdiction based on purchases the plaintiff made solely to create a local injury.
Ricoh Co., Ltd. v. Asustek Computer, Inc. · filed 2007-04-03(4)
I agree with defendants that plaintiffs purchases do not provide a basis for exercising jurisdiction under § 801.05(4). ... It is undisputed that plaintiff purchased defendants’ products for the sole purpose of providing a basis for personal jurisdiction.Read the full opinion on CourtListener →
Section 801.05(3) permits personal jurisdiction for injury arising from an act or omission in Wisconsin, including an owner’s alleged use of a deficient valve or failure to maintain it there.
Bruzek, Jasen v. Superior Refining Company LLC · filed 2019-09-30(3)
Pursuant to the state’s long-arm statute, Wisconsin may exercise personal jurisdiction over a defendant “[i]n any action claiming injury to person or property within or without this state arising out of an act or omission within this state by the defendant.” Wis. Stat. § 801.05(3). Taking the complaint as true and drawing all inferences in plaintiffs’ favor, HEI’s use of a deficient valve, as owner of the Refinery, would certainly appear to qualify as an act committed within the state of Wisconsin. Alternatively, HEI’s failure to maintain that valve could constitute an omission by the defendant within the state of Wisconsin.Read the full opinion on CourtListener →
Section 801.05(4)(a) confers personal jurisdiction when an out-of-state defendant’s acts cause injury in Wisconsin and the defendant provides service activities in Wisconsin, including through a website.
Webber v. Armslist LLC · filed 2021-11-09(4)(a)
Wisconsin’s long-arm statute confers jurisdiction where there was injury to a person within Wisconsin arising out of “an act or omission outside [Wisconsin] by the defendant, provided in addition that at the time of the injury . . . [s]olicitation or service activities were carried on within [Wisconsin] by or on behalf of the defendant.” Wis. Stat. 801.05(4)(a). ... Thus, the Court concludes that Wis. Stat. § 801.05(4)(a) confers jurisdiction over Armslist.Read the full opinion on CourtListener →
Section 801.05(4)(b) permits personal jurisdiction for out-of-state acts causing injury in Wisconsin when the defendant’s products are used or consumed there in the ordinary course of trade; sales of allegedly infringing products in Wisconsin satisfy that condition.
J.J. Keller & Associates, Inc. v. Tradex Global · filed 2026-02-12(4)(b)
Thus, even if the infringement occurs in another state, infringement of a copyright owned by a Wisconsin resident results in an injury in Wisconsin, thus satisfying the first part of Wis. Stat. § 801.05(4). The second part of the statute, specifically paragraph (b), is satisfied because Tradex sold at least two of each of the allegedly infringing products in Wisconsin.Read the full opinion on CourtListener →
Section 801.05(3) permits personal jurisdiction when alleged misrepresentations sent into Wisconsin by email cause injury there.
White Hair Solutions LLC v. Ingenuity Consulting Services LLC · filed 2024-03-15(3)
The Seventh Circuit has found that injury through electronic communications satisfies Wis. Stat. § 801.05(3). ... In short, White Hair has established a prima facie case for personal jurisdiction under Wis. Stat. § 801.05(3).Read the full opinion on CourtListener →
Section 801.05(3) supports a prima facie showing of personal jurisdiction when the defendant allegedly entered Wisconsin to solicit the transaction underlying a fraud claim.
Milwaukee World Trading LLC v. Kapsch · filed 2024-07-15(3)
The plaintiff has alleged that there was a local act or omission under §801.05(3) because the defendant “physically entered the state of Wisconsin for meetings in Kenosha to solicit the plaintiff to engage in the actions listed in this complaint and to engage in the business that the fraudulent statements listed in this complaint are associated with.” ... Drawing all reasonable inferences in favor of the plaintiff, the plaintiff has made a prima facie case for the exercise of personal jurisdiction.Read the full opinion on CourtListener →
Section 801.05(3) requires an act in Wisconsin by the defendant or an agent; a public official’s independent actions do not satisfy that requirement.
Nelson v. Eugene N. Bulso, Jr. · filed 1998-07-22(3)
And we have concluded that the defendant himself did not act in Wisconsin by directing the actions of Wisconsin officials. Subsection 3 of the long-arm statute does not apply.Read the full opinion on CourtListener →
Section 801.05(3) requires a local act or omission by the defendant; the plaintiff’s residence in the forum alone does not suffice.
Milwaukee Concrete Studios, Ltd. v. Fjeld Manufacturing Co. · filed 1991-12-20(3)
There is simply no evidence of a “local act or omission” on the part of the defendants within this district that would cause the court to apply Wis.Stat. § 801.05(3).Read the full opinion on CourtListener →
Section 801.05(3) bases personal jurisdiction on the defendant's act or omission within Wisconsin, regardless of where the plaintiff was injured.
Milwaukee Concrete Studios, Limited v. Fjeld Manufacturing Company, Incorporated, and Janice Krueger · filed 1993-10-19(3)
But section 801.05(3) of the Wisconsin long-arm statute, upon which MCS primarily relies, focuses on the defendant's "act or omission," not on the location of the plaintiff's injury.Read the full opinion on CourtListener →
Section 801.05(3) does not authorize personal jurisdiction for a failure to warn when the alleged omission occurred outside Wisconsin.
Hodgson v. Mississippi Department of Corrections · filed 1997-04-30(3)
Any failure to warn or to comply with the Uniform Act for Out-of-State Parolee Supervision on the part of Lucas and Bennett would have occurred in Mississippi, so subsection 801.05(3) does not authorize personal jurisdiction over them.Read the full opinion on CourtListener →
Section 801.05(3) permits personal jurisdiction when defendants, directly or through agents, commit acts in Wisconsin that injure another’s property.
Select Creations, Inc. v. Paliafito America, Inc. · filed 1995-12-18(3)
This Court has personal jurisdiction over Composto and Forman because the undisputed facts set forth herein establish that they, individually, and through their agents, committed acts within Wisconsin that gave rise to injury to Paliafito’s property. Wis. Stat. § 801.05(3).Read the full opinion on CourtListener →
Section 801.05(3) requires an act or omission in Wisconsin by the nonresident defendant; a plaintiff’s Wisconsin residence does not satisfy that requirement.
Cote v. Peter J. Wadel and Wadel & Bulger, P.C. · filed 1986-07-21(3)
Unfortunately for Coté there was no act or omission in Wisconsin by Wadel or other persons in his firm. The act or omission of which Coté complains is the failure to prosecute her suit and to cooperate with the lawyer whom she asked to investigate the failure, and these failures occurred in Michigan.Read the full opinion on CourtListener →
Section 801.05(3) does not confer personal jurisdiction based on two phone calls to people in Wisconsin because the calls are not acts within the state.
Cram v. Medical College of Wisconsin · filed 1996-02-20(3)
I do not believe that two phone calls to individuals in the state constitutes “an act or omission within this state.” ... In my opinion, such acts are insufficient to bring the Auerbach defendants within the purview of § 801.05(3).Read the full opinion on CourtListener →
Section 801.05(4) extends to the limits of due process and covers a Wisconsin injury when the defendant’s products are consumed there in the ordinary course of trade.
Giotis v. Apollo of the Ozarks, Inc. · filed 1986-09-04(4)
Asserting personal jurisdiction over defendants is consistent with the language of Wis.Stat. § 801.05(4); the injury occurred in Wisconsin, and as our due process analysis below demonstrates, the fireworks were consumed within Wisconsin in the ordinary course of trade. However, we need not linger over the construction of this statute, in view of our decision that the reach of Wis.Stat. § 801.05(4) is intended to be coextensive with the requirements of due process.Read the full opinion on CourtListener →
Section 801.05(3) requires an act or omission in Wisconsin, while § 801.05(4)(a) and (b) require qualifying activity beyond the out-of-state act that caused injury in Wisconsin.
Dietrich Ex Rel. Padway v. Wisconsin Patients Compensation Fund · filed 1992-05-12(3), (4)(a), (4)(b)
We conclude as a matter of law that Dr. Peacock committed no "act or omission" in Wisconsin within the scope of sec. 801.05(3), Stats. ... We further conclude that subsections 801.05(4)(a) and (b), Stats., are inapplicable because the words "in addition" unambiguously require some activity other than the act or omission outside Wisconsin giving rise to an injury here.Read the full opinion on CourtListener →
Section 801.05(4) permits jurisdiction for a Wisconsin injury arising from a foreign act when the manufacturer’s products are used in Wisconsin in the ordinary course of trade or its distributor conducts solicitation or service there on its behalf.
Schmitz v. Hunter MacHinery Co. · filed 1979-05-30(4)(a) and (b)
Under the facts of this case both the requirements of sec. 262.05(4) (a) and (b), Stats. (1973), and the traditional notions of fair play and substantial justice are amply satisfied.Read the full opinion on CourtListener →
Section 801.05(3) requires an act or omission within Wisconsin by the defendant; the out-of-state transfer and alleged failure to warn in this case did not qualify.
Lincoln Ex Rel. Hurley v. Seawright · filed 1981-10-06(3)
All we decide here is that, in this case, Seawright’s actions did not constitute an “act or omission within this state” for the purposes of sec. 801.05(3), Stats.Read the full opinion on CourtListener →
Section 801.05(3) permits personal jurisdiction when an out-of-state defendant’s acts in Wisconsin, including supervision of therapy there, give rise to the claimed injury.
Sawyer v. Midelfort · filed 1998-03-17(3)
The supervision of a Wisconsin therapist giving therapy in Wisconsin to a Wisconsin resident is an act occurring within Wisconsin. ... Cumulatively, these contacts bring Midelfort under Wisconsin jurisdiction pursuant to our liberal construction of § 801.05(3).Read the full opinion on CourtListener →
Personal jurisdiction over federal officials
Section 801.05 permits personal jurisdiction over an LLC member when allegations of the member’s own conduct make a prima facie showing under the long-arm statute.
William K Langfan Revocable Trust v. Foot Locker Specialty Inc · filed 2022-08-12
I find that Foot Locker has made a prima facie showing that Farrey falls within the grasp of Wisconsin’s long-arm statute. Foot Locker does not merely allege that Farrey was acting as an officer of JP-RAP when he performed his alleged actions; it alleges that Farrey was using the limited liability company to perpetrate a fraud and breach of contract against Foot Locker.Read the full opinion on CourtListener →
Subsection (10) is not the exclusive basis for personal jurisdiction over an insurer; other grounds in § 801.05 may apply.
Milwaukee County v. Hartford Casualty Co. · filed 1989-06-21(10)
Since we conclude that sec. 801.05(10), Stats., is not the exclusive means to vest a trial court with personal jurisdiction over an insurance company, we must examine the rest of sec. 801.05 to determine if personal jurisdiction exists.Read the full opinion on CourtListener →
Federal Rule 25(c) joinder
Section 801.05’s long-arm limitations do not constrain jurisdiction resulting from effective service under Federal Rule 25 without extraterritorial service.
Select Creations, Inc. v. Paliafito America, Inc. · filed 1994-04-27
The Han respondents argue that Paliafito failed effectively to serve them, and, in any event could not have done so pursuant to Rule 4(f), Fed.R.Civ.,P., or Wis.Stat. § 801.05, and in accordance with due process. (Post-Hearing Brief at 7-9.) As noted above, however, service effectively was made pursuant to Rule 25 on all but Min Suk Han. So doing, Paliafito did not rely on extraterritorial service. Our resulting jurisdiction, moreover, is not subject to either the limitations of the Wisconsin long-árm statute or the minimum contacts doctrine.Read the full opinion on CourtListener →
Personal jurisdiction in marital actions
Section 801.05 does not confer personal jurisdiction over nonresident defendants when the claims involve no Wisconsin goods, services, contracts, or property and allege no injury or injury-causing act in Wisconsin.
Houston v. Stucker · filed 2022-05-26
The plaintiff’s claims do not involve goods, services, contracts or property in the state of Wisconsin, and the complaint does not allege that any injury or any of the acts causing injury occurred in this state. Based on the complaint and the defendants’ undisputed declarations, Wisconsin’s long-arm jurisdictional statute does not confer personal jurisdiction over either defendant.Read the full opinion on CourtListener →
Section 801.05(1)(d) can provide personal jurisdiction in a divorce action seeking child support, maintenance, and attorney fees; qualifying activities are not limited to business or employment.
In RE MARRIAGE OF BUSHELMAN v. Bushelman · filed 2001-05-03(1)(d)
We conclude the plain language of WlS. Stat. §§ 767.05, 801.05(1) and (11), when read together, provide that § 801.05(l)(d) may be a basis for personal jurisdiction over a respondent in a divorce action seeking child support, maintenance, and attorney fees, and the activities that may satisfy the requirements of para. (l)(d) are not limited to business or employment related activities.Read the full opinion on CourtListener →
Section 801.05(1) and (11) did not authorize personal jurisdiction over a nonresident spouse who had not lived in Wisconsin within the statutory period and had no qualifying local presence or activity.
Haeuser v. Haeuser · filed 1995-02-24(1), (11)
Under the undisputed facts of this case, it is clear that neither Wisconsin’s “long-arm” statute nor its jurisdictional statute concerning “certain marital actions” authorized the assertion of personal jurisdiction over the husband. Consequently, Wisconsin did not have personal jurisdiction over the husband.Read the full opinion on CourtListener →
Section 801.05(11) provides an independent basis for personal jurisdiction in a family action; its six-months-within-six-years requirement need not be met when jurisdiction exists under § 801.05(1) or § 801.06.
In RE MARRIAGE OF McALEAVY v. McAleavy · filed 1989-06-07(11)
Contrary to John McAleavy's argument to this court, sec. 801.05(11), Stats., provides three independent sources of personal jurisdiction: the six month within six years test stated in sec. 801.05(11) and the additional, alternative sources of personal jurisdiction set forth in sec. 801.05(1) and sec. 801.06.Read the full opinion on CourtListener →
Section 801.05(11) limits personal jurisdiction over a respondent facing a personal claim in an action affecting the family based on where the action was commenced, the parties' marital residence, and personal service.
In Re Marriage of Thompson · filed 1986-02-11(11)
Personal jurisdiction to hear actions affecting the family ... is limited, where personal claims are asserted, to those cases meeting specified residence and status requirements.Read the full opinion on CourtListener →
Fraud exception to transient jurisdiction
Section 801.05(1)(a) permits jurisdiction based on in-state service, and setting aside that service under the fraud exception requires actual fraud; settlement negotiations alone do not suffice.
Manitowoc Western Co., Inc. v. Montonen · filed 2002-02-27(1)(a)
We agree with the dissent in Western States that the better rule is to continue to require a showing of actual fraud when a party seeks to set aside service under the fraud exception to the transient rule.Read the full opinion on CourtListener →
Child custody jurisdiction
Section 801.05(11) makes a Wisconsin child custody decree binding on an out-of-state parent who receives proper notice and an opportunity to be heard, even without minimum contacts.
Tammie J.C. v. Robert T.R. · filed 2003-06-20(11)
We think that the language of Wis. Stat. § 801.05(11) is clearit provides that a child custody decree issued by a Wisconsin court is binding on a person outside of Wisconsin provided that (1) the court has personal jurisdiction over the person, or (2) the person received proper notice of the court's exercise of jurisdiction, and was afforded an opportunity to be heard.Read the full opinion on CourtListener →
Personal service in Wisconsin
Section 801.05(1)(a) supports jurisdiction over an individual personally served in Wisconsin when the suit arises from his alleged tortious act in the state, even if he acted as a corporate officer.
Oxmans' Erwin Meat Co. v. Blacketer · filed 1979-01-09(1)(a)
If Wisconsin might constitutionally have extended jurisdiction over Blacketer by service outside the state (sec. 801.05(3), Stats.) for his act or omission within the state, Wisconsin’s exercise of jurisdiction over Blacketer by personal service within the state (sec. 801.05(1) (a), Stats.) cannot be offensive to constitutional principles in this case.Read the full opinion on CourtListener →
Personal jurisdiction over insurers
Section 801.05(10) provides personal jurisdiction over an insurer whose liability insurance promise covers the claim, even when that promise appears in a reinsurance treaty.
Ott v. All-Star Insurance Corp. · filed 1981-01-06(10)
Under the contract set forth in Addendum 5, North Star is subject to the jurisdiction of Wisconsin’s courts by virtue of sec. 801.05(10), Stats. (see also sec. 618.01 (3) and to joinder under sec. 803.04 (2)).Read the full opinion on CourtListener →
60 more cases cited this section only in passing
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