Wisconsin Statutes

Wis. Stat. § 135.02 (2026)

Definitions

✓ current as of July 2026
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135.02135.02Definitions. In this chapter:
135.02(1)(1)“Community of interest” means a continuing financial interest between the grantor and grantee in either the operation of the dealership business or the marketing of such goods or services.
135.02(2)(2)“Dealer” means a person who is a grantee of a dealership situated in this state.
135.02(3)(3)“Dealership” means any of the following:
135.02(3)(a)(a) A contract or agreement, either expressed or implied, whether oral or written, between 2 or more persons, by which a person is granted the right to sell or distribute goods or services, or use a trade name, trademark, service mark, logotype, advertising or other commercial symbol, in which there is a community of interest in the business of offering, selling or distributing goods or services at wholesale, retail, by lease, agreement or otherwise.
135.02(3)(b)(b) A contract or agreement, either expressed or implied, whether oral or written, between 2 or more persons by which a wholesaler, as defined in s. 125.02 (21), is granted the right to sell or distribute intoxicating liquor or use a trade name, trademark, service mark, logotype, advertising or other commercial symbol related to intoxicating liquor. This paragraph does not apply to dealerships described in s. 135.066 (5) (a) and (b).
135.02(4)(4)“Good cause” means:
135.02(4)(a)(a) Failure by a dealer to comply substantially with essential and reasonable requirements imposed upon the dealer by the grantor, or sought to be imposed by the grantor, which requirements are not discriminatory as compared with requirements imposed on other similarly situated dealers either by their terms or in the manner of their enforcement; or
135.02(4)(b)(b) Bad faith by the dealer in carrying out the terms of the dealership.
135.02(5)(5)“Grantor” means a person who grants a dealership.
135.02(6)(6)“Person” means a natural person, partnership, joint venture, corporation or other entity.
135.02 AnnotationA cartage agreement between an air freight company and a trucking company did not create a “dealership” under this chapter. Kania v. Airborne Freight Corp., 99 Wis. 2d 746, 300 N.W.2d 63 (1981).
135.02 AnnotationA manufacturer’s representative was not a “dealership.” Foerster, Inc. v. Atlas Metal Parts Co., 105 Wis. 2d 17, 313 N.W.2d 60 (1981).
135.02 AnnotationThis chapter applies exclusively to dealerships that do business within the geographic confines of the state. Swan Sales Corp. v. Jos. Schlitz Brewing Co., 126 Wis. 2d 16, 374 N.W.2d 640 (Ct. App. 1985).
135.02 AnnotationTwo guideposts for determining the existence of a “community of interest” under sub. (3) are: 1) a shared financial interest in the operation of the dealership or the marketing of a good or service; and 2) the degree of cooperation, coordination of activities, and sharing of common goals in the parties’ relationship. Ziegler Co., Inc. v. Rexnord, Inc., 139 Wis. 2d 593, 407 N.W.2d 873 (1987).
135.02 AnnotationA substantial investment distinguishes a dealership from a typical vendee-vendor relationship; establishing a loss of future profits is not sufficient. Gunderjohn v. Loewen-America, Inc., 179 Wis. 2d 201, 507 N.W.2d 115 (Ct. App. 1993).
135.02 AnnotationContracts between an HMO and chiropractors for the provision of chiropractic services to HMO members did not did not establish the chiropractors as dealerships under this chapter. Bakke Chiropractic Clinic v. Physicians Plus Insurance, 215 Wis. 2d 605, 573 N.W.2d 542 (Ct. App.1997), 97-1169.
135.02 AnnotationA dealership is a contract or agreement establishing a particular sort of commercial relationship that encompasses an extraordinary diverse set of business relationships not limited to the traditional franchise. The focus of the analysis must be on whether the business relationship can be said to be situated in the state after examining a broad set of factors outlined by the court. Baldewein Co. v. Tri-Clover, Inc., 2000 WI 20, 233 Wis. 2d 57, 606 N.W.2d 145, 99-0541. See also Baldewein Co. v. Tri-Clover, Inc., 183 F. Supp. 2d 1116 (2002).
135.02 AnnotationAssuming without deciding that the size of the local economy relative to the cost of the putative dealer’s inventory of the grantor’s products is a relevant factor in determining the existence of a community of interest, that factor did not demonstrate the existence of a community of interest in this case. Moe v. Benelli U.S.A. Corp., 2007 WI App 254, 306 Wis. 2d 812, 743 N.W.2d 691, 06-1512.
135.02 AnnotationUnder sub. (2), a “dealer” is defined in this chapter to mean “a person who is a grantee of a dealership situated in this state.” Sub. (3) defines “dealership” in part as “contract or agreement . . . between 2 or more persons, by which a person is granted the right to sell or distribute goods or services . . . .” Sub. (6) defines “person” as “a natural person, partnership, joint venture, corporation or other entity” and a city is a municipal corporation. Under s. 990.01 (26), “person” includes all partnerships, associations, and bodies politic and corporate. The general term “corporation” presumptively should be read to include more specific types of corporations. Under the facts of this case, the relationships between the defendant city and the golf pro plaintiffs who operated its golf courses constituted “dealerships” under sub. (3). Benson v. City of Madison, 2017 WI 65, 376 Wis. 2d 35, 897 N.W.2d 16, 15-2366.
135.02 AnnotationA wine grantor-dealer relationship is not included within the definition of a dealership in sub. (3) (b). Section 135.066 (2) provides the operative definition of intoxicating liquor for purposes of this chapter, and that definition explicitly excludes wine. Winebow, Inc. v. Capitol-Husting Co., Inc., 2018 WI 60, 381 Wis. 2d 732, 914 N.W.2d 631, 17-1595.
135.02 AnnotationWhen an otherwise protected party transfers a protected interest to a third party, a “community of interest” is destroyed and the party removed from WFDL protection. Lakefield Telephone Co. v. Northern Telecom, Inc., 970 F.2d 392 (1992).
135.02 AnnotationA community of interest exists when a large proportion of a dealer’s revenues are derived from the dealership, or when the alleged dealer has made sizable investments specialized in the grantor’s goods or services. Frieburg Farm Equip. v. Van Dale, Inc. 978 F.2d 395 (1992).
135.02 AnnotationThere is no “community of interest” in the sale of services not yet in existence when the availability of the services is dependent on the happening of an uncertain condition. Simos v. Embassy Suites, Inc., 983 F.2d 1404 (1993).
135.02 AnnotationThis chapter does not protect a manufacturer’s representative that lacks the unqualified authorization to sell or the authority to commit the manufacturer to a sale. Sales & Marketing Assoc., Inc. v. Huffy Corp., 57 F.3d 602 (1995).
135.02 AnnotationIf a grantor is losing substantial money under the dealership relationship, it may constitute “good cause” for changes in the contract, including termination. Morley-Murphy Co. v. Zenith Electronics, Inc., 142 F.3d 373 (1998).
135.02 AnnotationThis chapter specifies who may take advantage of its protections through the terms “dealer” and “dealership” and obviates the need to resort to conflict of laws principles. Investment in the state without in-state sales does not bring a party within the coverage of the chapter. Generac Corp. v. Caterpillar, Inc., 172 F.3d 971 (1999).
135.02 AnnotationA manufacturer’s right of approval of its distributors’ subdistributors did not create a contractual relationship between the manufacturer and the subdistributor subject to this chapter. Praefke Auto Electric & Battery Co. v. Tecumseh Products Co., 255 F.3d 460 (2001).
135.02 AnnotationThe WFDL expresses no concern for the mission or other motivation underlying the sales in question; it asks only whether sales occur. Nor does the statute draw any distinction between for-profit and not-for-profit entities. The stated concern is with fair business relations, and it is beyond dispute that nonprofit corporations can be substantial businesses. It matters not whether the purported dealer would be called a “dealer” in everyday conversation; what matters is only how the statute defines the term. Girl Scouts of Manitou Council, Inc. v. Girl Scouts of the United States of America, Inc., 549 F.3d 1079 (2008).
135.02 AnnotationAffirmed in part, reversed in part. 646 F.3d 983 (2011).
135.02 AnnotationFor an entity to qualify as a dealership through the use of commercial symbols, more is required than the mere right to use a commercial symbol. Instead, a dealership must either put those symbols to such use that the public associates the dealer with the trademark or prominently display the logo as an implicit guarantee of quality. Such use by a dealership ties its fortunes to the reputation of the grantor, giving the grantor superior bargaining power that the grantor might use to exploit the dealer. Sufficiently substantial use of a grantor’s corporate symbol typically requires a purported dealer to make a substantial investment in the trademark. PMT Machinery Sales, Inc. v. Yama Seiki USA, Inc., 941 F.3d 325 (2019).
135.02 AnnotationThe distinction between a dealer and a manufacturer’s representative is discussed. Al Bishop Agency, Inc. v. Lithonia-Division of National Services, Inc., 474 F. Supp. 828 (1979).
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135.02 AnnotationThe employment relationship in question was not a “dealership.” O’Leary v. Sterling Extruder Corp., 533 F. Supp. 1205 (1982).
135.02 AnnotationThe plaintiff was not a “dealer” since money advanced to the company for fixtures and inventory was refundable. Moore v. Tandy Corp. Radio Shack Div., 631 F. Supp. 1037 (1986).
135.02 AnnotationIt is improper to determine whether under sub. (3) a “community of interest” exists by examining the effect termination has on a division of the plaintiff. United States v. Davis, 756 F. Supp. 1162 (1990).
135.02 AnnotationThe plaintiff’s investment in “goodwill” was not sufficient to afford it protection under this chapter. Team Electronics v. Apple Computer, 773 F. Supp. 153 (1991).
135.02 AnnotationThe “situated in this state” requirement under sub. (2) is satisfied as long as the dealership conducts business in Wisconsin. CSS-Wisconsin Office v. Houston Satellite Systems, 779 F. Supp. 979 (1991).
135.02 AnnotationThere is no “community of interest” under sub. (3) when there is an utter absence of “shared goals” or “cooperative coordinated efforts” between the parties. Cajan of Wisconsin v. Winston Furniture Co., 817 F. Supp 778 (1993).
135.02 AnnotationEven if a person is granted a right to sell a product, the person is not a dealer unless that person actually sells the product. Smith v. Rainsoft, 848 F. Supp. 1413 (1994).
135.02 AnnotationUnder sub. (3), de minimus use of a trade name or mark is insufficient: there must be substantial investment in it. Satellite Receivers v. Household Bank, 922 F. Supp. 174 (1996).
135.02 AnnotationA clause providing that the party who had drafted the contract and dictated all of its provisions was not a party to the contract was void, and that party was a grantor of a dealership. Praefke Auto Electric & Battery Co. v. Tecumseh Products, Co., 110 F. Supp. 2d 899 (2000).
135.02 AnnotationNothing in the text or legislative history of this chapter suggests that the legislature intended to preclude co-ops from being dealers. Sub. (2) defines a dealer as “a person who is a grantee of a dealership.” Sub. (6) defines a person as a “corporation or other entity.” Under s. 185.02, a co-op is “an association incorporated” in the state. Thus a co-op is a corporation or other entity within sub. (6) and subject to this chapter. Builder’s World, Inc. v. Marvin Lumber & Cedar, Inc., 482 F. Supp. 2d 1065 (2007).
135.02 AnnotationIn determining whether a plaintiff has a right to sell under the WFDL, the most important factor is the dealer’s ability to transfer the product itself, or title to the product, or commit the grantor to a transaction at the moment of the agreement to sell. A manufacturer’s representative, defined as an independent contractor who solicits orders for a manufacturer’s product from potential customers and is paid a commission on resulting sales, is a position consistently excluded from the WFDL. Northland Sales, Inc. v. Maax Corp., 556 F. Supp. 2d 928 (2008). See also PMT Machinery Sales, Inc. v. Yama Seiki USA, Inc., 941 F.3d 325 (2019).
135.02 AnnotationIn search of a dealership definition: The teachings of Bush and Ziegler. Carter & Kendall. WBB Apr. 1988.
135.02 AnnotationThe Wisconsin Fair Dealership Law’s Territorial Imperative. Keeler. Wis. Law. Aug. 1999.
Notes of Decisions
Cited in 132 cases (9 in the last 5 years), 1965–2026 · leading case: Winebow, Inc. v. Capitol-Husting Co., Inc., 914 N.W.2d 631 (Wis. 2018).
Winebow, Inc. v. Capitol-Husting Co., Inc., 914 N.W.2d 631 (Wis. 2018). · cites it 85× “¶4 We conclude that a wine grantor-dealer relationship is not included within the definition of a dealership in Wis. Stat. § 135.02 (3)(b). Section 135.066(2) provides the operative definition of "intoxicating liquor" for purposes of ch.”
Thomas F. Benson v. City of Madison, 2017 WI 65 (Wis. 2017). · cites it 54× “See Wis. Stat. § 135.02 (3). The Golf Pros appealed, and the court of appeals affirmed.”
Baldewein Co. v. Tri-Clover, Inc., 2000 WI 20 (Wis. 2000). · cites it 30× “The essential question is: when is a dealership "situated in this state" under Wis. Stat. § 135.02 (2), [1] thereby entitling the dealer to protection under the Wisconsin Fair Dealership Law (WFDL)? [2] Based upon the language of the statute, as well as its history and purposes,…”
Bush v. Nat'l Sch. Studios, Inc., 407 N.W.2d 883 (Wis. 1987). · cites it 14× “Whether there is a dealership by that section depends principally on whether "there is a community of interest in the business.”
Cent. Corp. v. Rsch. Prods. Corp., 2004 WI 76 (Wis. 2004). · cites it 12× “In its complaint, Central stated that there was a community of interest, as contemplated in Wis. Stat. § 135.02 (3) (a) (2001-02), 1 between itself and Research "because there is a continuing financial interest between the parties in the sale and distribution of these goods and…”
Ziegler Co., Inc. v. Rexnord, 433 N.W.2d 8 (Wis. 1988). · cites it 14× “Section 135.02(4) defines good cause to mean that the dealer has failed to carry out an important part of its responsibilities.”
Foerster, Inc. v. Atlas Metal Parts Co., 313 N.W.2d 60 (Wis. 1981). · cites it 10× “The judgment dismissed the amended complaint of the plaintiff-appellant-petitioner, Foerster, Incorporated, holding that it was not a “dealership” as defined in sec. 135.02(2), Stats., and, thus, not entitled to the protections of the Wisconsin Fair Dealership Law when the…”
Al Bishop Agency, Inc. v. Lithonia-Div. of Nat'l Serv. Indus., Inc., 474 F. Supp. 828 (E.D. Wis. 1979). · cites it 14× “A “dealership” as defined by Wis. Stat. § 135.02 (2): [Mjeans a contract or agreement, either expressed or implied, whether oral or written, between 2 or more persons, by *831 which a person is granted the right to sell or distribute goods or services, or use a trade name,…”
Girl Scouts of Manitou Council, Inc. v. Girl Scouts of United States of Am., Inc., 549 F.3d 1079 (7th Cir. 2008). · cites it 3× “The District Court’s Statutory Conclusions As further support for its conclusion that Manitou would not suffer irreparable harm, the district court disagreed with Manitou’s argument that it was a “dealer” protected by the Wisconsin Fair Dealership Law, Wis. Stat. § 135.02 (2),…”
Les Moise, Inc. v. Rossignol Ski Co., Inc., 361 N.W.2d 653 (Wis. 1985). · cites it 17× “02(3), and provides: "`Dealership' means a contract or agreement, either expressed or implied, whether oral or written, between 2 or more persons, by which a person is granted the right to sell or distribute goods or services, or use a trade name, trademark, service mark,…”
Winebow, Inc. v. Capitol-Husting Co., Inc., 867 F.3d 862 (7th Cir. 2017). · cites it 13× “Whether they are correct depends on the language of that statute, to which we now turn.”
Bong v. Cerny, 463 N.W.2d 359 (Wis. Ct. App. 1990). · cites it 17× “Tech Rubber permits its distributors to use jobbers. The primary issue raised by the defendants' motion for summary judgment is whether Tech Rubber or Cerny is a "grantor" of a "dealership” to the Bongs under sec.”
— Wis. Stat. § 135.02(1) — 17 cases
Thomas F. Benson v. City of Madison, 2017 WI 65 (Wis. 2017). “See Wis. Stat. § 135.02 (3). The Golf Pros appealed, and the court of appeals affirmed.”
Bush v. Nat'l Sch. Studios, Inc., 407 N.W.2d 883 (Wis. 1987). “Whether there is a dealership by that section depends principally on whether "there is a community of interest in the business.”
Cent. Corp. v. Rsch. Prods. Corp., 2004 WI 76 (Wis. 2004). “In its complaint, Central stated that there was a community of interest, as contemplated in Wis. Stat. § 135.02 (3) (a) (2001-02), 1 between itself and Research "because there is a continuing financial interest between the parties in the sale and distribution of these goods and…”
Guderjohn v. Loewen-Am., Inc., 507 N.W.2d 115 (Wis. Ct. App. 1993).
S+L+H S.p.A. v. Miller-St. Nazianz, Inc., 988 F.2d 1518 (7th Cir. 1993).
— Wis. Stat. § 135.02(2) — 35 cases
Foerster, Inc. v. Atlas Metal Parts Co., 313 N.W.2d 60 (Wis. 1981). “The judgment dismissed the amended complaint of the plaintiff-appellant-petitioner, Foerster, Incorporated, holding that it was not a “dealership” as defined in sec. 135.02(2), Stats., and, thus, not entitled to the protections of the Wisconsin Fair Dealership Law when the…”
E. A. Dickinson & Assocs., Inc. v. Simpson Elec. Co., 509 F. Supp. 1241 (E.D. Wis. 1981).
Al Bishop Agency, Inc. v. Lithonia-Div. of Nat'l Serv. Indus., Inc., 474 F. Supp. 828 (E.D. Wis. 1979). “A “dealership” as defined by Wis. Stat. § 135.02 (2): [Mjeans a contract or agreement, either expressed or implied, whether oral or written, between 2 or more persons, by *831 which a person is granted the right to sell or distribute goods or services, or use a trade name,…”
Thomas F. Benson v. City of Madison, 2017 WI 65 (Wis. 2017). “See Wis. Stat. § 135.02 (3). The Golf Pros appealed, and the court of appeals affirmed.”
Les Moise, Inc. v. Rossignol Ski Co., Inc., 361 N.W.2d 653 (Wis. 1985). “02(3), and provides: "`Dealership' means a contract or agreement, either expressed or implied, whether oral or written, between 2 or more persons, by which a person is granted the right to sell or distribute goods or services, or use a trade name, trademark, service mark,…”
— Wis. Stat. § 135.02(3) — 25 cases
Bush v. Nat'l Sch. Studios, Inc., 407 N.W.2d 883 (Wis. 1987). “Whether there is a dealership by that section depends principally on whether "there is a community of interest in the business.”
Bong v. Cerny, 463 N.W.2d 359 (Wis. Ct. App. 1990). “Tech Rubber permits its distributors to use jobbers. The primary issue raised by the defendants' motion for summary judgment is whether Tech Rubber or Cerny is a "grantor" of a "dealership” to the Bongs under sec.”
Bakke Chiropractic Clinic v. Physicians Plus Ins. Corp., 573 N.W.2d 542 (Wis. Ct. App. 1997).
Les Moise, Inc. v. Rossignol Ski Co., Inc., 361 N.W.2d 653 (Wis. 1985). “02(3), and provides: "`Dealership' means a contract or agreement, either expressed or implied, whether oral or written, between 2 or more persons, by which a person is granted the right to sell or distribute goods or services, or use a trade name, trademark, service mark,…”
Superview Network, Inc. v. SuperAmerica, 827 F. Supp. 1392 (E.D. Wis. 1993).
— Wis. Stat. § 135.02(3)(a) — 7 cases
Thomas F. Benson v. City of Madison, 2017 WI 65 (Wis. 2017). “See Wis. Stat. § 135.02 (3). The Golf Pros appealed, and the court of appeals affirmed.”
Cent. Corp. v. Rsch. Prods. Corp., 2004 WI 76 (Wis. 2004). “In its complaint, Central stated that there was a community of interest, as contemplated in Wis. Stat. § 135.02 (3) (a) (2001-02), 1 between itself and Research "because there is a continuing financial interest between the parties in the sale and distribution of these goods and…”
Praefke Auto Elec. & Battery Co. v. Tecumseh Prods. Co., 110 F. Supp. 2d 899 (E.D. Wis. 2000).
Builder's World, Inc. v. Marvin Lumber & Cedar, Inc., 482 F. Supp. 2d 1065 (E.D. Wis. 2007).
Water Quality Store, LLC v. Dynasty Spas, Inc., 2010 WI App 112 (Wis. Ct. App. 2010).
— Wis. Stat. § 135.02(3)(b) — 1 case
Winebow, Inc. v. Capitol-Husting Co., Inc., 914 N.W.2d 631 (Wis. 2018). “¶4 We conclude that a wine grantor-dealer relationship is not included within the definition of a dealership in Wis. Stat. § 135.02 (3)(b). Section 135.066(2) provides the operative definition of "intoxicating liquor" for purposes of ch.”
— Wis. Stat. § 135.02(4) — 15 cases
Ziegler Co., Inc. v. Rexnord, 433 N.W.2d 8 (Wis. 1988). “Section 135.02(4) defines good cause to mean that the dealer has failed to carry out an important part of its responsibilities.”
Kania v. Airborne Freight Corp., 300 N.W.2d 63 (Wis. 1981).
Lee Beverage Co. v. I.S.C. Wines of California, Inc., 623 F. Supp. 867 (E.D. Wis. 1985).
H. Phillips Co. v. Brown-Forman Distillers Corp., 483 F. Supp. 1289 (W.D. Wis. 1980).
Moore v. Tandy Corp., Radio Shack Div., 631 F. Supp. 1037 (W.D. Wis. 1986).
— Wis. Stat. § 135.02(4)(a) — 7 cases
Ziegler Co., Inc. v. Rexnord, 433 N.W.2d 8 (Wis. 1988). “Section 135.02(4) defines good cause to mean that the dealer has failed to carry out an important part of its responsibilities.”
Frieburg Farm Equip., Inc. v. Van Dale, Inc., 756 F. Supp. 1191 (W.D. Wis. 1991).
Morley-Murphy Co. v. Zenith Elec. Corp., 910 F. Supp. 450 (W.D. Wis. 1996).
Ferguson-Kubly Indus. Servs., Inc. v. Circle Env't, Inc., 409 F. Supp. 2d 1072 (E.D. Wis. 2006).
Romper Room Inc. v. Winmark Corp., 60 F. Supp. 3d 993 (E.D. Wis. 2014).
— Wis. Stat. § 135.02(5) — 6 cases
Bong v. Cerny, 463 N.W.2d 359 (Wis. Ct. App. 1990). “Tech Rubber permits its distributors to use jobbers. The primary issue raised by the defendants' motion for summary judgment is whether Tech Rubber or Cerny is a "grantor" of a "dealership” to the Bongs under sec.”
Les Moise, Inc. v. Rossignol Ski Co., Inc., 361 N.W.2d 653 (Wis. 1985). “02(3), and provides: "`Dealership' means a contract or agreement, either expressed or implied, whether oral or written, between 2 or more persons, by which a person is granted the right to sell or distribute goods or services, or use a trade name, trademark, service mark,…”
Wilburn v. Jack Cartwright, Inc., 514 F. Supp. 493 (E.D. Wis. 1981).
Praefke Auto Elec. & Battery Co. v. Tecumseh Prods. Co., 110 F. Supp. 2d 899 (E.D. Wis. 2000).
L-O Distributors, Inc. v. Speed Queen Co., 611 F. Supp. 1569 (D. Minnesota 1985).
— Wis. Stat. § 135.02(6) — 10 cases
Al Bishop Agency, Inc. v. Lithonia-Div. of Nat'l Serv. Indus., Inc., 474 F. Supp. 828 (E.D. Wis. 1979). “A “dealership” as defined by Wis. Stat. § 135.02 (2): [Mjeans a contract or agreement, either expressed or implied, whether oral or written, between 2 or more persons, by *831 which a person is granted the right to sell or distribute goods or services, or use a trade name,…”
Van v. Mobil Oil Corp., 515 F. Supp. 487 (E.D. Wis. 1981).
CL Thompson Co., Inc. v. Festo Corp., 708 F. Supp. 221 (E.D. Wis. 1989).
St. Joseph Equip. v. Massey-Ferguson, Inc., 546 F. Supp. 1245 (W.D. Wis. 1982).
Bresler's 33 Flavors Franchising Corp. v. Wokosin, 591 F. Supp. 1533 (E.D. Wis. 1984).
— Wis. Stat. § 135.02(a) — 1 case
L-O Distributors, Inc. v. Speed Queen Co., 611 F. Supp. 1569 (D. Minnesota 1985).
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.