reliance standard (Wisconsin) · Go Syfert
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reliance standard in Wisconsin

11 Wisconsin opinions name it 2 courts 1985–2025 6 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 (4)

CaseFollowedCited
Ottman v. Town of Primrosegreen
wis · 2011 · cited in 2 Wisconsin opinions naming this issue, 2025–2025
2 sentences

2025See Ottman v Town of Primrose, 2011 WI 18, ¶51 , 332 Wis. 2d 3 , 796 N.W.2d 411 .

2025See Ottman v Town of Primrose, 2011 WI 18, ¶51 , 332 Wis. 2d 3 , 796 N.W.2d 411 .

22
United States v. Lanegreen
ca7 · 1984 · cited in 1 Wisconsin opinions naming this issue, 2006–2006
2 sentences

2006While not explicitly addressing the issue of harmless error, the Court stated that "the real question here is ... whether the sentence in the 1953 federal case might have been different if the sentencing judge had known that at least two of the respondent's previous convictions had been unconstitutionally obtained." Id. (footnote omitted). ¶ 13 The actual reliance standard was subsequently followed by the Seventh Circuit Court of Appeals in Welch v. Lane, 738 F.2d 863 (7th Cir.1984).

2006The actual reliance standard was subsequently followed by the Seventh Circuit Court of Appeals in Welch v. Lane, 738 F.2d 863 (7th Cir. 1984).

11
State Ex Rel. Enterprise Realty Co. v. Swiderskigreen
wis · 1955 · cited in 1 Wisconsin opinions naming this issue, 1988–1988
2 sentences

1988Enterprise Realty Co. v. Swiderski, 269 Wis. 642, 645 , 70 N.W.2d 34, 35 (1955). > HH VALUATION OF THE CRANBERRY BEDS The taxpayers contend that the fair market value of their cranberry beds was established by the comparable sales and that the assessor’s reliance on factors outside those sales was contrary to sec. 70.32(1), Stats.

1988Enterprise Realty Co. v. Swiderski, 269 Wis. 642, 645 , 70 N.W.2d 34, 35 (1955). > HH VALUATION OF THE CRANBERRY BEDS The taxpayers contend that the fair market value of their cranberry beds was established by the comparable sales and that the assessor’s reliance on factors outside those sales was contrary to sec. 70.32(1), Stats.

11
Charlie Benson Bowen v. Ralph Kemp, Warden, Georgia Diagnostic and Classification Center, Respondentgreen
ca11 · 1985 · cited in 1 Wisconsin opinions naming this issue, 1986–1986
1 sentence

1986For a more recent example of this approach, see Bowen v. Kemp, 769 F.2d 672, 677 (11th Cir.) (1985), in which the federal court of appeals ruled that the defendant's reliance on the defense of insanity conceded the intent element of the charged crime, making an unconstitutional presumption in the instruction on intent harmless error.

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 (7)

CaseCitedYears
WTMJ, Inc. v. Sullivan green
wisctapp · 1996
2 sentences

2022E.g., WTMJ, Inc. v. Sullivan, 204 Wis. 2d 452, 458 , 555 N.W.2d 140 (Ct. App. 1996) (quoting State ex rel.

2022E.g., WTMJ, Inc. v. Sullivan, 204 Wis. 2d 452, 458 , 555 N.W.2d 140 (Ct. App. 1996) (quoting State ex rel.

22022–2022
State v. Eric L. Loomis green
wis · 2016
1 sentence

2025Id.

12025–2025
Friends of Frame Park, U.A. v. City of Waukesha green
wisctapp · 2020
1 sentence

2023The test stated in the opinion of this court in Friends of Frame Park, U.A. v. City of Waukesha, 2020 WI App 61 , 394 Wis. 2d 387 , 950 N.W.2d 831 , is summarized in the majority opinion: [This] court stated that the requesting party is entitled to attorney fees when “it demonstrates a violation of [the public records law]; that is, an unreasonable delay caused by the improper reliance on an exception.” Id.

12023–2023
United States v. Tucker green
scotus · 1972
1 sentence

2006While not explicitly addressing the issue of harmless error, the Court stated that "the real question here is ... whether the sentence in the 1953 federal case might have been different if the sentencing judge had known that at least two of the respondent's previous convictions had been unconstitutionally obtained." Id. (footnote omitted). ¶ 13 The actual reliance standard was subsequently followed by the Seventh Circuit Court of Appeals in Welch v. Lane, 738 F.2d 863 (7th Cir.1984).

12006–2006
State v. Johnson green
wisctapp · 1990
2 sentences

2006Whether the court "actually relied" on the incorrect information at sentencing was based upon whether the court gave "explicit attention" or "specific consideration" to it, so that the misinformation "formed part of the basis for the sentence." Id. at 866. ¶ 15 An examination of case law in Wisconsin reveals that, although the actual reliance standard was properly formulated, initially, the court of appeals began to stray from that standard in some cases by requiring the proof of prejudicial, rather than actual reliance. ¶ 16 In Johnson, 158 Wis.2d 458 , 463 N.W.2d 352 , the defendant requeste

2006Whether the court "actually relied" on the incorrect information at sentencing was based upon whether the court gave "explicit attention" or "specific consideration" to it, so that the misinformation "formed part of the basis for the sentence." Id. at 866. ¶ 15 An examination of case law in Wisconsin reveals that, although the actual reliance standard was properly formulated, initially, the court of appeals began to stray from that standard in some cases by requiring the proof of prejudicial, rather than actual reliance. ¶ 16 In Johnson, 158 Wis.2d 458 , 463 N.W.2d 352 , the defendant requeste

12006–2006
Ramsden v. Farm Credit Services of North Central Wisconsin ACA green
wisctapp · 1998
2 sentences

2001Ramsden v. Farm Credit Servs., 223 Wis. 2d 704, 721 , 590 N.W.2d 1 (Ct. App. 1998).

2001Ramsden v. Farm Credit Servs., 223 Wis. 2d 704, 721 , 590 N.W.2d 1 (Ct. App. 1998).

12001–2001
State Ex Rel. Flowers v. Department of Health & Social Services green
wis · 1978
2 sentences

1985Flowers v. H&SS Dept., 81 Wis. 2d 376, 387 , 260 N.W.2d 727 (1978), denominated this reliance as error, because relitigation of an issue is precluded in a second proceeding on an estoppel theory only “ ‘where the matter raised in the second suit is identical in all respects with that decided in the first proceeding and where the controlling facts and applicable legal rules remain unchanged ....’” (Ct. App. slip opinion at page 4.) The court of appeals pointed out that reasonableness of a refusal is not an issue in a refusal hearing — only the question of whether the test was refused “due to a

1985Flowers v. H&SS Dept., 81 Wis. 2d 376, 387 , 260 N.W.2d 727 (1978), denominated this reliance as error, because relitigation of an issue is precluded in a second proceeding on an estoppel theory only “ ‘where the matter raised in the second suit is identical in all respects with that decided in the first proceeding and where the controlling facts and applicable legal rules remain unchanged ....’” (Ct. App. slip opinion at page 4.) The court of appeals pointed out that reasonableness of a refusal is not an issue in a refusal hearing — only the question of whether the test was refused “due to a

11985–1985

Statutes the citing opinions construe

WI § Wis. Stat. § 808.10 (4) WI § Wis. Stat. § 19.31 (3) WI § Wis. Stat. § 19.32 (3) WI § Wis. Stat. § 19.35 (3) WI § Wis. Stat. § 19.36 (3) WI § Wis. Stat. § 19.37 (3) WI § Wis. Stat. § 19.85 (3) WI § Wis. Stat. § 802.08 (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 75 (1964–2026) NY 30 (1906–2025) IL 26 (1977–2024) PA 23 (1980–2025) TX 18 (1978–2022) WA 18 (1986–2026) AL 16 (1991–2025) CT 15 (1995–2024) MA 14 (1960–2025) MD 14 (1969–2024) FL 14 (1973–2020) NJ 12 (1981–2022) WI 11 (1985–2025) MI 9 (1978–2024) UT 8 (1995–2026) GA 8 (1978–2026) OH 8 (1966–2018) AZ 7 (1973–2020) DC 7 (1979–2022) LA 7 (1985–2017) VT 6 (1967–2018) NM 6 (2000–2021) NC 6 (1986–2020) ID 6 (1979–2021) NE 5 (1988–2024) AK 5 (1976–1989) OR 5 (2001–2012) MN 5 (1971–2017) CO 5 (1994–2026) TN 4 (1995–2014) NV 4 (1957–2014) IA 4 (2006–2018) WV 4 (1980–2017) RI 4 (2002–2023) IN 4 (1978–2023) VA 4 (2008–2018) MO 3 (1966–2017) KS 3 (1972–2008) MS 2 (2007–2007) HI 2 (1996–2017) KY 2 (2011–2026) SC 2 (2000–2011) SD 2 (2004–2009) VI 2 (2009–2011) ME 2 (2007–2012) ND 2 (1976–2018) NH 2 (1997–2005)

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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