preemption analysis (Wisconsin) · Go Syfert
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preemption analysis in Wisconsin

31 Wisconsin opinions name it 3 courts 1980–2025 3 in the last five years

The cases below were cited by Wisconsin courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (18)

CaseFollowedCited
Aguayo v. U.S. Bankgreen
ca9 · 2011 · cited in 2 Wisconsin opinions naming this issue, 2025–2025
2 sentences

2025Co. v. Dedeaux, 481 U.S. 41, 51 (1987) (citations and quotation marks omitted). ¶29 In a preemption analysis, the reviewing court must “read a statute or regulation in its entirety” and when applied, as occurs here, the court must “consider both the express preemption and savings clauses together.” Aguayo v. U.S. Bank, 653 F.3d 912, 922 (9th Cir. 2011).

2025Co. v. Dedeaux, 481 U.S. 41, 51 (1987) (citations and quotation marks omitted). ¶29 In a preemption analysis, the reviewing court must “read a statute or regulation in its entirety” and when applied, as occurs here, the court must “consider both the express preemption and savings clauses together.” Aguayo v. U.S. Bank, 653 F.3d 912, 922 (9th Cir. 2011).

22
Pilot Life Insurance v. Dedeauxgreen
scotus · 1987 · cited in 2 Wisconsin opinions naming this issue, 2025–2025
2 sentences

2025Co. v. Dedeaux, 481 U.S. 41, 51 (1987) (citations and quotation marks omitted). ¶29 In a preemption analysis, the reviewing court must “read a statute or regulation in its entirety” and when applied, as occurs here, the court must “consider both the express preemption and savings clauses together.” Aguayo v. U.S. Bank, 653 F.3d 912, 922 (9th Cir. 2011).

2025Co. v. Dedeaux, 481 U.S. 41, 51 (1987) (citations and quotation marks omitted). ¶29 In a preemption analysis, the reviewing court must “read a statute or regulation in its entirety” and when applied, as occurs here, the court must “consider both the express preemption and savings clauses together.” Aguayo v. U.S. Bank, 653 F.3d 912, 922 (9th Cir. 2011).

22
Medtronic, Inc. v. Lohrgreen
scotus · 1996 · cited in 2 Wisconsin opinions naming this issue, 2003–2011
2 sentences

2011See Medtronic, Inc. v. Lohr, 518 U.S. 470, 485 (1996) (in the context of a preemption analysis under another federal statute, recognizing the "historic primacy of state regulation of matters of health and safety"). ¶ 91.

2003The preemption clause there was similar to the one here, and provided, as material: *510 "[N]o State . . . may establish or continue in effect with respect to a device intended for human use any requirement— (1) which is different from, or in addition to, any requirement applicable under this chapter to the device, and (2) which relates to the safety or effectiveness of the device or to any other matter included in a requirement applicable to the device under this chapter." Id., 518 U.S. at 481-482 .

22
Gross v. Hoffmangreen
wis · 1938 · cited in 2 Wisconsin opinions naming this issue, 2003–2006
2 sentences

2006See Gross v. Hoffman, 227 Wis. 296, 300 , 277 N.W. 663 (1938) (only dispositive issues need be addressed).

2006See Gross v. Hoffman, 227 Wis. 296, 300 , 277 N.W. 663 (1938) (only dispositive issues need be addressed).

22
Ramah Navajo School Bd., Inc. v. Bureau of Revenue of NMgreen
scotus · 1982 · cited in 2 Wisconsin opinions naming this issue, 1986–1992
2 sentences

1992In each case, the court must conduct a "particularized examination of the relevant state, federal, and tribal interests." Cotton Petroleum Corp. v. New Mexico, 109 S. Ct. 1698, 1707 (1989) (quoting Ramah Navajo School Board v. Bureau of Revenue of New Mexico, 458 U.S. 832, 838 (1982)).

1992First, I agree with the majority's reading of White Mountain Apache Tribe v. Bracker, 448 U.S. 136 (1980), and Ramah Navajo School Board v. Bureau of Revenue of New Mexico, 458 U.S. 832 (1982).

12
Ledger v. City of Waupaca Board of Appealsgreen
wisctapp · 1988 · cited in 1 Wisconsin opinions naming this issue, 2024–2024
1 sentence

2024See Ledger, 146 Wis. 2d at 262-66 .

11
Norfolk Southern Railway Co. v. Shanklingreen
scotus · 2000 · cited in 1 Wisconsin opinions naming this issue, 2019–2019
1 sentence

2019See id.

11
unempl.ins.rep. (Cch) P 22,142 in Re Hollytex Carpet Mills, Inc., Debtor. Hollytex Carpet Mills, Inc. v. Oklahoma Employment Security Commissiongreen
ca10 · 1996 · cited in 1 Wisconsin opinions naming this issue, 2015–2015
1 sentence

2015See Hollytex, 73 F.3d at 1522-23 .

11
State v. Blalockgreen
wisctapp · 1989 · cited in 1 Wisconsin opinions naming this issue, 2003–2003
2 sentences

2003See Gross v. Hoffman, 227 Wis. 296, 300 , 277 N.W. 663, 665 (1938) (only dispositive issue need be addressed); State v. Blalock, 150 Wis. 2d 688, 703 , 442 N.W.2d 514, 520 (Ct. App. 1989) (cases should be decided on the "narrowest possible ground").

2003See Gross v. Hoffman, 227 Wis. 296, 300 , 277 N.W. 663, 665 (1938) (only dispositive issue need be addressed); State v. Blalock, 150 Wis. 2d 688, 703 , 442 N.W.2d 514, 520 (Ct. App. 1989) (cases should be decided on the "narrowest possible ground").

11
Morales v. Trans World Airlines, Inc.green
scotus · 1992 · cited in 1 Wisconsin opinions naming this issue, 1996–1996
1 sentence

1996See generally id.

11
cluster 584519green
ca3 · 1992 · cited in 1 Wisconsin opinions naming this issue, 1994–1994
2 sentences

1994Pursuant to the preemption doctrine, federal law supersedes state law in three general situations: "[W]here Congress explicitly preempts state law, where preemption is implied because Congress has occupied the entire field and where preemption is implied because there is an actual conflict between' federal and state law." Buzzard v. Roadrunner Trucking, Inc., 966 F.2d 777, 779-80 (3d Cir. 1992).

1994Id. at 780 .

11
Thompson v. Village of Hales Cornersgreen
wis · 1983 · cited in 1 Wisconsin opinions naming this issue, 1994–1994
2 sentences

1994VI, cl. 2, provides: This Constitution, and the Laws of the United States which shall be made in Pursuance thereof; and all Treaties made, or which shall be made, under the Authority of the United States, shall be the supreme Law of the Land; and the Judges in every State shall be bound thereby, any Thing in the Constitution or Laws of any State to the Contrary notwithstanding. 4 While federal court decisions, other than United States Supreme Court decisions on questions of federal law, are not binding on us, Thompson v. Hales Corners, 115 Wis. 2d 289, 307 , 340 N.W.2d 704, 713 (1983), we may

1994VI, cl. 2, provides: This Constitution, and the Laws of the United States which shall be made in Pursuance thereof; and all Treaties made, or which shall be made, under the Authority of the United States, shall be the supreme Law of the Land; and the Judges in every State shall be bound thereby, any Thing in the Constitution or Laws of any State to the Contrary notwithstanding. 4 While federal court decisions, other than United States Supreme Court decisions on questions of federal law, are not binding on us, Thompson v. Hales Corners, 115 Wis. 2d 289, 307 , 340 N.W.2d 704, 713 (1983), we may

11
Cotton Petroleum Corp. v. New Mexicogreen
scotus · 1989 · cited in 1 Wisconsin opinions naming this issue, 1992–1992
2 sentences

1992Under the preemption analysis developed by the U.S. Supreme Court in federal Indian law cases, we must avoid rigidly applying "mechanical or absolute conceptions of state or tribal sovereignty . . .." White Mountain, 448 U.S. at 145 . " [Questions of pre-emption in this area are not resolved by reference to standards of preemption that have developed in other areas of the law . . .." Cotton Petroleum Corp. v. New Mexico, 490 U.S. 163, 176 (1989).

1992In sum, "the relevant preemption test is a flexible one sensitive to the particular state, federal, and tribal interests involved." Cotton, 109 S. Ct. at 1711 .

11
Brown v. Hotel & Restaurant Employees & Bartenders International Union Local 54green
scotus · 1984 · cited in 1 Wisconsin opinions naming this issue, 1992–1992
1 sentence

1992The focus of a preemption inquiry is whether "Congress has explicitly mandated the pre-emption of state law or has adequately indicated an intent to occupy the field of regulation, thereby displacing all state laws on the same subject." Brown v. Hotel and Restaurant Employees and Bartenders Int'l Union Local 54, 468 U.S. 491, 500-01 (1984) (citations omitted).

11
cluster 389201green
ca9 · 1981 · cited in 1 Wisconsin opinions naming this issue, 1986–1986
11
Penn Dairies, Inc. v. Milk Control Comm'n of Pa.green
scotus · 1943 · cited in 1 Wisconsin opinions naming this issue, 1985–1985
11
Rice v. Santa Fe Elevator Corp.green
scotus · 1947 · cited in 1 Wisconsin opinions naming this issue, 1985–1985
11
Hines v. Davidowitzgreen
scotus · 1941 · cited in 1 Wisconsin opinions naming this issue, 1983–1983
11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Wisconsin. Read the followed side critically anyway.

Also cited on this issue (20)

CaseCitedYears
Anchor Savings & Loan Ass'n v. Equal Opportunities Commission green
wis · 1984
2 sentences

2012We refer to the four-factor preemption test as the "Anchor test" because it first appeared, in its modern form, in Anchor Sav. & Loan Ass'n v. Equal Opportunities Comm'n, 120 Wis. 2d 391 , 355 N.W.2d 234 (1984).

2012We refer to the four-factor preemption test as the "Anchor test" because it first appeared, in its modern form, in Anchor Sav. & Loan Ass'n v. Equal Opportunities Comm'n, 120 Wis. 2d 391 , 355 N.W.2d 234 (1984).

31996–2012
State Ex Rel. Kalal v. Circuit Court for Dane County green
wis · 2004
2 sentences

2025Kalal v. Circuit Ct. for Dane Cnty., 2004 WI 58, ¶45 , 271 Wis. 2d 633 , 681 N.W.2d 110 . 10 A preemption inquiry generally begins with the question of whether the federal law fully occupied the field with its actions.

2025Kalal v. Circuit Ct. for Dane Cnty., 2004 WI 58, ¶45 , 271 Wis. 2d 633 , 681 N.W.2d 110 . 10 A preemption inquiry generally begins with the question of whether the federal law fully occupied the field with its actions.

22025–2025
DeRosso Landfill Co. v. City of Oak Creek green
wis · 1996
2 sentences

2010American Transmission Co. v. Dane County, 2009 WI App 126, ¶ 9 , 321 Wis. 2d 138 , 772 N.W.2d 731 (citing DeRosso Landfill Co. v. City of Oak Creek, 200 Wis. 2d 642, 657 , 547 N.W.2d 770 (1996)).

2010American Transmission Co. v. Dane County, 2009 WI App 126, ¶ 9 , 321 Wis. 2d 138 , 772 N.W.2d 731 (citing DeRosso Landfill Co. v. City of Oak Creek, 200 Wis. 2d 642, 657 , 547 N.W.2d 770 (1996)).

22009–2010
Sprietsma v. Mercury Marine green
scotus · 2002
2 sentences

2009Id. at 65-68 .

2003Furthermore, insofar as the preemption doctrine implicates a federal need for uniformity of regulation, see Sprietsma, 123 S. Ct. at 523 , the federal inspection scheme here eschews uniformity in favor of non-uniform plant-by-plant Hazard Analysis and Critical Control Point plans developed by the plant operators themselves.

22003–2009
White Mountain Apache Tribe v. Bracker green
scotus · 1980
2 sentences

1992Under the preemption analysis developed by the U.S. Supreme Court in federal Indian law cases, we must avoid rigidly applying "mechanical or absolute conceptions of state or tribal sovereignty . . .." White Mountain, 448 U.S. at 145 . " [Questions of pre-emption in this area are not resolved by reference to standards of preemption that have developed in other areas of the law . . .." Cotton Petroleum Corp. v. New Mexico, 490 U.S. 163, 176 (1989).

1992We do not agree. [7-9] Under the preemption analysis developed by the U.S. Supreme Court in federal Indian law cases, we must avoid rigidly applying "mechanical or absolute conceptions of state or tribal sovereignty...." White Mountain, 448 U.S. at 145 . "[Q]uestions of pre-emption in this area are not resolved by reference to standards of preemption that have developed in other areas of the law ...." Cotton Petroleum Corp. v. New Mexico, 490 U.S. 163, 176 (1989).

21986–1992
Rice v. Rehner green
scotus · 1983
2 sentences

1988The court of appeals utilized the preemption analysis articulated in Rice v. Rehner, 463 U.S. 713 (1983), and State v. Webster, 114 Wis. 2d 418, 338 N.W.2d 474 (1983), in reaching its conclusion.

1986Id. at 725 . *433 Applying the second stage of the preemption analysis, the Rice Court found no federal preemption because the federal statute allowing tribal liquor regulation also allowed concurrent state regulation.

21986–1988
CSX Transportation, Inc. v. Easterwood green
scotus · 1993
1 sentence

2014On the contrary, in CSX Transportation, Inc. v. Easterwood, 507 U.S. 658 (1993), the case the majority opinion cites for the "specific, individual hazard" exception, the United States Supreme Court acknowledged that preemption of an excessive speed claim under the Federal Railroad Safety Act "does not bar suit for breach of related tort law duties .... " 8 A "specific, individual hazard" is not to be confused with the preemption exception in § 20106(a)(2)(A) for an "essentially local safety or security hazard." 9 ¶ 64.

12014–2014
Metropolitan Life Insurance v. Massachusetts green
scotus · 1985
1 sentence

2011The Machinists doctrine "protects against state interference with policies implicated by the structure of the [NLRA] itself, by preempting state law and state causes of action concerning conduct that Congress intended to be unregulated." Metropolitan Life, 471 U.S. at 749 .

12011–2011
American Transmission Co. v. Dane County green
wisctapp · 2009
2 sentences

2010American Transmission Co. v. Dane County, 2009 WI App 126, ¶ 9 , 321 Wis. 2d 138 , 772 N.W.2d 731 (citing DeRosso Landfill Co. v. City of Oak Creek, 200 Wis. 2d 642, 657 , 547 N.W.2d 770 (1996)).

2010American Transmission Co. v. Dane County, 2009 WI App 126, ¶ 9 , 321 Wis. 2d 138 , 772 N.W.2d 731 (citing DeRosso Landfill Co. v. City of Oak Creek, 200 Wis. 2d 642, 657 , 547 N.W.2d 770 (1996)).

12010–2010
Riegel v. Medtronic, Inc. green
scotus · 2008
2 sentences

2009The third question is whether the preemption analysis of Riegel v. Medtronic, Inc., ___ U.S. ___, 128 S.Ct. 999 , 169 L.Ed.2d 892 (2008), applies to claims against the Marquis 7230 defibrillator, even though supplemental premarket approval [4] was given to a later *399 defibrillator.

2009The third question is whether the preemption analysis of Riegel v. Medtronic, Inc., _ U.S. _, 128 S. Ct. 999 (2008), applies to claims against the Marquis 7230 defibrillator, even though supplemental premarket approval 4 was given to a later defibrillator.

12009–2009
Cipollone v. Liggett Group, Inc. green
scotus · 1992
1 sentence

2005Id. at 525-27 .

12005–2005
Felder v. Casey green
scotus · 1988
1 sentence

2005Felder, 487 U.S. at 138 .

12005–2005
Boggs v. Boggs green
scotus · 1997
1 sentence

2000The majority found it unnecessary to "inquire whether the statutory phrase 'relate to' provides further and additional support for the preemption claim." Id.

12000–2000
DeRosso Landfill Co. v. City of Oak Creek green
wisctapp · 1995
1 sentence

1996DeRosso, 191 Wis. 2d at 64-65 .

11996–1996
Louisiana Pub. Serv. Comm'n v. FCC green
scotus · 1986
1 sentence

1990Pre-emption occurs when Congress, in enacting a federal statute, expresses a clear intent to pre-empt state law, when there is outright or actual conflict between federal and state law, where compliance with both federal and state law is in effect physically impossible, where there is implicit in federal law a barrier to state regulation, where Congress has legislated comprehensively, thus occupying an entire field of regulation and leaving no room for the States to supplement federal law, or where the state law stands as an obstacle to the accomplishment and execution of the full objectives o

11990–1990
MacKey v. Lanier Collection Agency & Service, Inc. green
scotus · 1988
1 sentence

1989While ERISA preempts states from interfering with such collection efforts, see Mackey, 108 S. Ct. at 2185 , it does not preempt states from creating general creditors' rights that may be utilized to effect collections of obligations by all creditors, including a creditor possessing an ERISA claim that has been reduced to a judgment.

11989–1989
State v. Webster green
wis · 1983
11988–1988
McClanahan v. Arizona State Tax Commission green
scotus · 1973
11986–1986
Wisconsin's Environmental Decade, Inc. v. Department of Natural Resources green
wis · 1978
11984–1984
Fox v. City of Racine green
wis · 1937
11980–1980

Statutes the citing opinions construe

WI § Wis. Stat. § 802.08 (8) USC § 49u.s.c.20106 (3) WI § Wis. Stat. § 62.11 (3) WI § Wis. Stat. § 808.10 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 277 (1911–2026) NY 112 (1981–2026) IL 101 (1974–2026) TX 93 (1969–2025) NJ 69 (1971–2026) PA 66 (1966–2025) OH 50 (1975–2026) MN 45 (1984–2019) TN 45 (1987–2022) IN 38 (1981–2024) MI 35 (1970–2025) CO 32 (1972–2025) WA 32 (1972–2021) NM 31 (1987–2019) WI 31 (1980–2025) AZ 30 (1971–2025) IA 30 (1978–2026) MD 29 (1977–2026) MA 27 (1964–2023) FL 24 (1962–2021) LA 23 (1962–2024) OK 20 (1986–2024) GA 19 (1991–2022) MO 19 (1971–2017) AL 17 (1964–2014) MT 16 (1977–2025) KS 16 (1922–2026) OR 14 (1985–2023) NV 14 (2000–2026) SC 13 (1984–2019) NC 13 (1973–2026) NH 13 (1995–2019) CT 12 (1990–2024) HI 12 (1982–2023) UT 11 (1992–2012) NE 10 (1982–2006) KY 10 (1979–2026) MS 9 (1968–2013) ID 9 (1979–2018) AK 8 (1967–2022) DE 8 (1980–2025) WV 7 (2009–2024) VT 7 (1988–2024) RI 7 (1985–2020) ME 6 (1989–2025) AR 5 (1984–2025) ND 5 (1991–2025) VA 5 (1985–2021) VI 4 (2010–2026) SD 4 (1977–2020) DC 3 (1986–2009) WY 2 (2014–2014) PR 2 (2023–2025)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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