voluntary payment doctrine (Wisconsin) · Go Syfert
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voluntary payment doctrine in Wisconsin

11 Wisconsin opinions name it 2 courts 2001–2023 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 (17)

CaseFollowedCited
Putnam v. Time Warner Cable of Southeastern Wisconsin, Ltd. Partnershipgreen
wis · 2002 · cited in 3 Wisconsin opinions naming this issue, 2006–2012
2 sentences

2006After the circuit court made this decision, the supreme court decided Putnam, 255 Wis. 2d 447 , which addressed the voluntary payment doctrine.

2006While recognizing that under Putnam, 255 Wis. 2d 447, ¶ 13 (citation omitted), the voluntary payment doctrine does not apply if there is "fraud or wrongful conduct inducing payment," the court found nothing in the pleadings alleging that the payments were induced by fraud or made under duress. ¶ 10.

23
G. Heileman Brewing Co. v. City of La Crossegreen
wisctapp · 1981 · cited in 3 Wisconsin opinions naming this issue, 2001–2012
2 sentences

2012Heileman Brewing Co. v. City of La Crosse, 105 Wis. 2d 152, 162 , 312 N.W.2d 875 (Ct. App. 1981), "the doctrine of voluntary payment," Frederick v. Douglas Cnty., 96 Wis. 411, 423 , 71 N.W. 798 (1897) (Winslow, J. concurring), or just "voluntary payment," Elliott v. Swartwout, 35 U.S. 137, 153 (1836).

2012Heileman Brewing Co. v. City of La Crosse, 105 Wis. 2d 152, 162 , 312 N.W.2d 875 (Ct. App. 1981), "the doctrine of voluntary payment," Frederick v. Douglas Cnty., 96 Wis. 411, 423 , 71 N.W. 798 (1897) (Winslow, J. concurring), or just "voluntary payment," Elliott v. Swartwout, 35 U.S. 137, 153 (1836).

13
MBS-Certified Public Accountants, LLC v. Wisconsin Bell Inc.green
wis · 2012 · cited in 2 Wisconsin opinions naming this issue, 2013–2019
2 sentences

2019In MBS-Certified Public Accountants, LLC v. Wisconsin Bell, Inc., 2012 WI 15, ¶31 , 338 Wis. 2d 647 , 809 N.W.2d 857 (alteration in original; citation omitted), our supreme court “described the nature and purpose of the voluntary payment doctrine as follows: ‘[M]oney paid voluntarily, with knowledge of all the facts, and without fraud or duress, cannot be recovered merely on account of ignorance or mistake of the law.’” Brown argues that the Plan voluntarily submitted payments for Brown’s medical care and “[n]ot once did the Plan challenge those payments before making them.” Many employee clai

2019In MBS-Certified Public Accountants, LLC v. Wisconsin Bell, Inc., 2012 WI 15, ¶31 , 338 Wis. 2d 647 , 809 N.W.2d 857 (alteration in original; citation omitted), our supreme court “described the nature and purpose of the voluntary payment doctrine as follows: ‘[M]oney paid voluntarily, with knowledge of all the facts, and without fraud or duress, cannot be recovered merely on account of ignorance or mistake of the law.’” Brown argues that the Plan voluntarily submitted payments for Brown’s medical care and “[n]ot once did the Plan challenge those payments before making them.” Many employee clai

12
Covenant Healthcare System, Inc. v. City of Wauwatosagreen
wis · 2011 · cited in 1 Wisconsin opinions naming this issue, 2021–2021
1 sentence

2021See Covenant Healthcare Sys., Inc., 336 Wis. 2d 522, ¶22 ; Kickers of Wis., Inc., 197 Wis. 2d at 680 .

11
Carolyn Moya v. Healthport Technologies, LLCgreen
wis · 2017 · cited in 1 Wisconsin opinions naming this issue, 2021–2021
2 sentences

2021Moya II, 375 Wis. 2d 38, ¶33 (citation omitted).

2021Thus, we believe this holding of Moya II to be broad enough to preclude application of the voluntary payment doctrine to these claims as well, because application of the doctrine to these claims would just as readily “undermine the manifest purposes” of § 146.83(3f).8 See Moya II, 375 Wis. 2d 38, ¶34 . ¶42 For the foregoing reasons, we conclude that the circuit court did not erroneously exercise its discretion in certifying the class in this case.

11
Nelson J. Elliott v. Samuel Swartwoutgreen
· 1836 · cited in 1 Wisconsin opinions naming this issue, 2012–2012
1 sentence

2012Heileman Brewing Co. v. City of La Crosse, 105 Wis. 2d 152, 162 , 312 N.W.2d 875 (Ct. App. 1981), "the doctrine of voluntary payment," Frederick v. Douglas Cnty., 96 Wis. 411, 423 , 71 N.W. 798 (1897) (Winslow, J. concurring), or just "voluntary payment," Elliott v. Swartwout, 35 U.S. 137, 153 (1836).

11
Webster v. Fallgreen
scotus · 1925 · cited in 1 Wisconsin opinions naming this issue, 2012–2012
1 sentence

2012Nevertheless, "questions which merely lurk in the record, neither brought to the attention of the court nor ruled upon, are not to be considered as having been so decided as to constitute precedents." Webster v. Fall, 266 U.S. 507, 511 (1925). 15 ¶ 35.

11
INDOOR BILLBOARD WASHINGTON, INC. v. Integra Telecom of Washington, Inc.green
wash · 2007 · cited in 1 Wisconsin opinions naming this issue, 2012–2012
2 sentences

2012See also Indoor Billboard/Washington, Inc. v. Integra Telecom of Washington, Inc., 170 P.3d 10 (Wash. 2007) (concluding that the voluntary payment doctrine was not a defense in a cramming case where the court construed the statute liberally in favor of plaintiffs); Sobel v. Hertz Corp., 698 F. Supp. 2d 1218 (D.

2012See also Indoor Billboard/Washington, Inc. v. Integra Telecom of Washington, Inc., 170 P.3d 10 (Wash. 2007) (concluding that the voluntary payment doctrine was not a defense in a cramming case where the court construed the statute liberally in favor of plaintiffs); Sobel v. Hertz Corp., 698 F. Supp. 2d 1218 (D.

11
State v. Achterberggreen
wis · 1996 · cited in 1 Wisconsin opinions naming this issue, 2012–2012
2 sentences

2012See State v. Achterberg, 201 Wis. 2d 291 , 300 n.5, 548 N.W.2d 515 (1996). ¶ 79.

2012See State v. Achterberg, 201 Wis. 2d 291 , 300 n.5, 548 N.W.2d 515 (1996). ¶ 79.

11
Wausau Tile, Inc. v. County Concrete Corp.green
wis · 1999 · cited in 1 Wisconsin opinions naming this issue, 2006–2006
2 sentences

2006See Wausau Tile, Inc. v. County Concrete Corp., 226 Wis. 2d 235, 245 , 593 N.W.2d 445 (1999). ¶ 14.

2006See Wausau Tile, Inc. v. County Concrete Corp., 226 Wis. 2d 235, 245 , 593 N.W.2d 445 (1999). ¶ 14.

11
Putnam v. Time Warner Cable of Southeastern Wisconsin, Ltd. Partnershipgreen
wisctapp · 2001 · cited in 1 Wisconsin opinions naming this issue, 2002–2002
2 sentences

2002In affirming both conclusions, the court of appeals advanced multiple reasons why, "regardless of the truthfulness of the customers' assertions, the voluntary payment doctrine precluded their claims for recovery of late-fee payments in excess of Time Warner's actual costs." Putnam v. Time Warner Cable of SE Wis., 2001 WI App 196, ¶ 9 , 247 Wis. 2d 41 , 633 N.W.2d 254 .

2002In affirming both conclusions, the court of appeals advanced multiple reasons why, "regardless of the truthfulness of the customers' assertions, the voluntary payment doctrine precluded their claims for recovery of late-fee payments in excess of Time Warner's actual costs." Putnam v. Time Warner Cable of SE Wis., 2001 WI App 196, ¶ 9 , 247 Wis. 2d 41 , 633 N.W.2d 254 .

11
Frank P. Randazzo, as Trustee for Frank P. Randazzo Declaration of Trust Dated July 18, 1997 v. Harris Bank Palatine, N.A.green
ca7 · 2001 · cited in 1 Wisconsin opinions naming this issue, 2002–2002
2 sentences

2002See Randazzo v. Harris Bank Palatine, N.A., 262 F.3d 663, 667-68 (7th Cir. 2001) (citing Stephen L.

2002See Randazzo v. Harris Bank Palatine, N.A., 262 F.3d 663, 667-68 (7th Cir. 2001) (citing Stephen L.

11
Horne v. Time Warner Operations, Inc.green
mssd · 1999 · cited in 1 Wisconsin opinions naming this issue, 2002–2002
2 sentences

2002See, e.g., Horne v. Time Warner Operations, 119 F.Supp. 2d 624 (S.D.

2002See, e.g., Horne v. Time Warner Operations, 119 F.Supp. 2d 624 (S.D.

11
Dillon v. U-A Columbia Cablevision of Westchester, Inc.green
nyappdiv · 2002 · cited in 1 Wisconsin opinions naming this issue, 2002–2002
1 sentence

2002See Dillon v. U-A Columbia Cablevision of Westchester, 740 N.Y.S.2d 396, 398 (N.Y App. Div. 2002) (using knowledge of these facts as a basis for denying recovery of unlawful late-payment fees by cable customers, under the voluntary payment doctrine).

11
Gage v. Allengreen
· 1894 · cited in 1 Wisconsin opinions naming this issue, 2002–2002
2 sentences

2002See Gage v. Allen, 89 Wis. 98 , 61 N.W. 361 (1894); Burgess v. Commercial Nat'l Bank, 144 Wis. 59 , 128 N.W. 436 (1910). [11] This holding is consistent with a number of nearly identical cases from other jurisdictions in which recovery of late fee payments to cable providers was barred by the voluntary payment doctrine.

2002See Gage v. Allen, 89 Wis. 98 , 61 N.W. 361 (1894); Burgess v. Commercial Nat'l Bank, 144 Wis. 59 , 128 N.W. 436 (1910). [11] This holding is consistent with a number of nearly identical cases from other jurisdictions in which recovery of late fee payments to cable providers was barred by the voluntary payment doctrine.

11
Smith v. Prime Cable of Chicagogreen
illappct · 1995 · cited in 1 Wisconsin opinions naming this issue, 2001–2001
11
Sorce v. Rinehartgreen
wis · 1975 · cited in 1 Wisconsin opinions naming this issue, 2001–2001
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 (19)

CaseCitedYears
Frederick v. Douglas County green
· 1897
2 sentences

2012Heileman Brewing Co. v. City of La Crosse, 105 Wis. 2d 152, 162 , 312 N.W.2d 875 (Ct. App. 1981), "the doctrine of voluntary payment," Frederick v. Douglas Cnty., 96 Wis. 411, 423 , 71 N.W. 798 (1897) (Winslow, J. concurring), or just "voluntary payment," Elliott v. Swartwout, 35 U.S. 137, 153 (1836).

2012Heileman Brewing Co. v. City of La Crosse, 105 Wis. 2d 152, 162 , 312 N.W.2d 875 (Ct. App. 1981), "the doctrine of voluntary payment," Frederick v. Douglas Cnty., 96 Wis. 411, 423 , 71 N.W. 798 (1897) (Winslow, J. concurring), or just "voluntary payment," Elliott v. Swartwout, 35 U.S. 137, 153 (1836).

32001–2012
Butcher v. Ameritech Corp. green
wisctapp · 2006
2 sentences

2013Cf. Butcher v. Ameritech Corp., 2007 WI App 5, ¶ 15 , 298 Wis. 2d 468 , 727 N.W.2d 546 (fraud a defense to the voluntary payment doctrine).

2013Cf. Butcher v. Ameritech Corp., 2007 WI App 5, ¶ 15 , 298 Wis. 2d 468 , 727 N.W.2d 546 (fraud a defense to the voluntary payment doctrine).

22012–2013
Derrick J. Hammetter v. Verisma Systems, Inc. green
wisctapp · 2021
2 sentences

2023Hammetter v. Verisma Sys., Inc., 2021 WI App 53, ¶¶39-41 , 399 Wis. 2d 211 , 963 N.W.2d 874 , review denied (WI Apr. 13, 2022) (No. 2019AP2423).

2023Hammetter v. Verisma Sys., Inc., 2021 WI App 53, ¶¶39-41 , 399 Wis. 2d 211 , 963 N.W.2d 874 , review denied (WI Apr. 13, 2022) (No. 2019AP2423).

12023–2023
Kickers of Wisconsin, Inc. v. City of Milwaukee green
wisctapp · 1995
1 sentence

2021See Covenant Healthcare Sys., Inc., 336 Wis. 2d 522, ¶22 ; Kickers of Wis., Inc., 197 Wis. 2d at 680 .

12021–2021
Udelhofen v. John Hancock Mutual Life Insurance green
wisctapp · 1985
2 sentences

2019Co., 128 Wis. 2d 216, 220 , 381 N.W.2d 579 (Ct. App. 1985).8 The circuit court properly granted summary judgment on the Plan’s counterclaim. 8 The Wisconsin Practice Series on Workers’ Compensation Law also explains: (continued) 12 No. 2018AP1799 ¶22 Brown next argues the voluntary payment doctrine.

2019Co., 128 Wis. 2d 216, 220 , 381 N.W.2d 579 (Ct. App. 1985).8 The circuit court properly granted summary judgment on the Plan’s counterclaim. 8 The Wisconsin Practice Series on Workers’ Compensation Law also explains: (continued) 12 No. 2018AP1799 ¶22 Brown next argues the voluntary payment doctrine.

12019–2019
Miller v. St. Mary's Regional Health Center green
minn · 2011
1 sentence

2013Johnson & Son, Inc. v. Morris, 2010 WI App 6, ¶ 33 , 322 Wis. 2d 766 , 799 N.W.2d 19 , the remedial provisions of the WOCCA are to be given "liberal construction." Given the statutory purpose and the mandate that the statute is to be construed broadly to effectuate its manifest purpose, we conclude that applying the voluntary payment doctrine would frustrate the purpose of the WOCCA.

12013–2013
S.C. Johnson & Son, Inc. v. Morris green
wisctapp · 2009
2 sentences

2013Johnson & Son, Inc. v. Morris, 2010 WI App 6, ¶ 33 , 322 Wis. 2d 766 , 799 N.W.2d 19 , the remedial provisions of the WOCCA are to be given "liberal construction." Given the statutory purpose and the mandate that the statute is to be construed broadly to effectuate its manifest purpose, we conclude that applying the voluntary payment doctrine would frustrate the purpose of the WOCCA.

2013Johnson & Son, Inc. v. Morris, 2010 WI App 6, ¶ 33 , 322 Wis. 2d 766 , 799 N.W.2d 19 , the remedial provisions of the WOCCA are to be given "liberal construction." Given the statutory purpose and the mandate that the statute is to be construed broadly to effectuate its manifest purpose, we conclude that applying the voluntary payment doctrine would frustrate the purpose of the WOCCA.

12013–2013
Spivey v. Adaptive Marketing LLC green
ca7 · 2010
2 sentences

2012Spivey v. Adaptive Marketing LLC, 622 F.3d 816 (7th Cir. 2010).

2012Id. at 822-24 . ¶ 92.

12012–2012
Fuchsgruber v. Custom Accessories, Inc. green
wis · 2001
2 sentences

2012Additionally, they contend that under the rule of Fuchsgruber v. Custom Accessories, Inc., 2001 WI 81 , 244 Wis. 2d 758 , 628 N.W.2d 833 , the legislature was required to make explicit reference to the voluntary payment doctrine in the text of Wis. Stat. § 100.207 if it intended the doctrine to be inapplicable to claims under that statute. ¶ 3.

2012Additionally, they contend that under the rule of Fuchsgruber v. Custom Accessories, Inc., 2001 WI 81 , 244 Wis. 2d 758 , 628 N.W.2d 833 , the legislature was required to make explicit reference to the voluntary payment doctrine in the text of Wis. Stat. § 100.207 if it intended the doctrine to be inapplicable to claims under that statute. ¶ 3.

12012–2012
Sobel v. Hertz Corp. green
nvd · 2010
2 sentences

2012See also Indoor Billboard/Washington, Inc. v. Integra Telecom of Washington, Inc., 170 P.3d 10 (Wash. 2007) (concluding that the voluntary payment doctrine was not a defense in a cramming case where the court construed the statute liberally in favor of plaintiffs); Sobel v. Hertz Corp., 698 F. Supp. 2d 1218 (D.

2012See also Indoor Billboard/Washington, Inc. v. Integra Telecom of Washington, Inc., 170 P.3d 10 (Wash. 2007) (concluding that the voluntary payment doctrine was not a defense in a cramming case where the court construed the statute liberally in favor of plaintiffs); Sobel v. Hertz Corp., 698 F. Supp. 2d 1218 (D.

12012–2012
Huch v. Charter Communications, Inc. green
mo · 2009
2 sentences

2012For example, in Huch v. Charter Communications, Inc., 290 S.W.3d 721 (Mo. 2009), a state administrative regulation prohibited the practice of billing for unsolicited merchandise.

2012In a statutory action for violation of the regulation, the Missouri supreme court concluded that the voluntary payment doctrine was inapplicable as a defense because the doctrine "would nullify the protections of the act and be contrary to the intent of the legislature." Id. at 727 .

12012–2012
State v. Hobson green
wis · 1998
2 sentences

2012But if the common law defense of the voluntary payment doctrine applies and you have this rare customer ... his payment was not the result of fraud, duress, or mistake of fact, then to get around the voluntary payment doctrine, that customer would have to protest." For example, in this case, the circuit court concluded that the voluntary payment doctrine was a viable defense to the claims for damages and then explained: "For the plaintiffs to claim that the voluntary payment doctrine does not apply on account of fraud, they must satisfy the court of three elements: First that there was a knowi

2012But if the common law defense of the voluntary payment doctrine applies and you have this rare customer ... his payment was not the result of fraud, duress, or mistake of fact, then to get around the voluntary payment doctrine, that customer would have to protest." For example, in this case, the circuit court concluded that the voluntary payment doctrine was a viable defense to the claims for damages and then explained: "For the plaintiffs to claim that the voluntary payment doctrine does not apply on account of fraud, they must satisfy the court of three elements: First that there was a knowi

12012–2012
State Ex Rel. Kalal v. Circuit Court for Dane County green
wis · 2004
1 sentence

2012A court's interpretation of a statute should not "contravene a textually or contextually manifest statutory purpose." Kalal, 271 Wis. 2d 633, ¶ 49 .

12012–2012
Shands v. Castrovinci green
wis · 1983
1 sentence

2012Applying the voluntary payment doctrine to bar many private rights of action could encourage cramming, the mischief the legislature sought to suppress, by eliminating "a necessary backup to the state's enforcement powers." See Shands, 115 Wis. 2d at 358-59 . ¶ 58.

12012–2012
Burgess v. Commercial National Bank of Appleton green
wis · 1910
2 sentences

2002See Gage v. Allen, 89 Wis. 98 , 61 N.W. 361 (1894); Burgess v. Commercial Nat'l Bank, 144 Wis. 59 , 128 N.W. 436 (1910). [11] This holding is consistent with a number of nearly identical cases from other jurisdictions in which recovery of late fee payments to cable providers was barred by the voluntary payment doctrine.

2002See Gage v. Allen, 89 Wis. 98 , 61 N.W. 361 (1894); Burgess v. Commercial Nat'l Bank, 144 Wis. 59 , 128 N.W. 436 (1910). [11] This holding is consistent with a number of nearly identical cases from other jurisdictions in which recovery of late fee payments to cable providers was barred by the voluntary payment doctrine.

12002–2002
Telescripps Cable Co. v. Welsh green
gactapp · 2000
12001–2001
Wassenaar v. Panos green
wis · 1983
12001–2001
Northwestern Motor Car, Inc. v. Pope green
wis · 1971
12001–2001
Brandt v. Labor & Industry Review Commission green
wisctapp · 1991
12001–2001

Statutes the citing opinions construe

WI § Wis. Stat. § 806.04 (4) WI § Wis. Stat. § 146.83 (3) WI § Wis. Stat. § 146.84 (3) WI § Wis. Stat. § 802.03 (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

IL 88 (1979–2026) TX 59 (1988–2026) NY 51 (2002–2025) GA 22 (1997–2025) MO 19 (2008–2021) AR 14 (1907–2024) WI 11 (2001–2023) AL 9 (1915–2013) WA 9 (2007–2021) VA 8 (2004–2025) MD 8 (1985–2019) NV 7 (2011–2019) PA 5 (2007–2015) FL 5 (1997–2018) IA 5 (2013–2023) CA 5 (1959–2023) MA 5 (1996–2025) IN 4 (2001–2016) TN 4 (1997–2018) NJ 4 (1995–2021) DE 4 (2019–2023) CO 4 (2005–2009) DC 3 (2006–2016) SC 3 (2012–2018) OK 2 (1999–2006) ID 2 (2013–2024) VT 2 (1997–2025) RI 2 (2000–2017) AZ 2 (2026–2026)

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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