Wisconsin Statutes
Wis. Stat. § 345.45 (2026)
Burden of proof
✓ current as of July 2026
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345.45345.45 Burden of proof. The standard of proof for conviction of any person charged with violation of any traffic regulation shall be evidence that is clear, satisfactory and convincing.
Notes of Decisions
Cited in 15
cases (11 in the last 5 years), 1980–2026 · leading case: State v. Albright, 298 N.W.2d 196 (Wis. Ct. App. 1980).
State v. Albright, 298 N.W.2d 196 (Wis. Ct. App. 1980). “Section 345.45 provides: “[T]he standard of proof for conviction of any person charged with violation of any traffic regulation shall be evidence that is clear, satisfactory and convincing.”
State v. Kiper, 532 N.W.2d 698 (Wis. 1995). “In 1992, Wanie was convicted, pursuant to § 345.45(1) of the Green Bay Code of Ordinances, of "permitting [an] unauthorized minor to drive.”
In Interest of RB, 322 N.W.2d 502 (Wis. Ct. App. 1982). “§ 345.45, Stats, (burden is clear, satisfactory, and convincing for purposes of traffic regulations); City of Milwaukee v.”
Waukesha Cnty. v. Stephen E. Lee (Wis. Ct. App. 2023). “§ 345.45. Additional facts relevant to the arguments Lee raises on appeal are provided below.”
State v. Joseph B. Venable (Wis. Ct. App. 2024). “§ 345.45 (setting forth the applicable burden of proof for civil traffic violations; see also County of Racine v.”
Dane Cnty. v. Trent Joseph Meyer (Wis. Ct. App. 2025). “” The statute further states that “[t]he speed of a vehicle shall be so controlled as may be necessary to avoid colliding with any object, person, vehicle[,] or other conveyance on or entering the highway in compliance with legal requirements and using due care.” § 346.57(2).…”
State v. Chris K. Feller (Wis. Ct. App. 2019). “The trooper was southbound on Interstate 39 in a marked vehicle, equipped with a radar unit, and driving at a steady speed of 70 m.”
City of Cedarburg v. Katherine D. Young (Wis. Ct. App. 2021). “§§ 345.45, 800.08(3), that the defendant “dr[o]ve or operate[d] a motor vehicle while … [u]nder the influence of an intoxicant,” WIS.”
Dodge Cnty. v. Cynthia M. Blandin (Wis. Ct. App. 2021). “§ 345.45 (standard of proof for conviction of a violation of a traffic regulation).”
State v. Jeffrey S. Wein (Wis. Ct. App. 2022). “§ 345.45. It proved this. ¶17 On a challenge to the sufficiency of the evidence, we “may not reverse a conviction unless the evidence, viewed most favorably to the state and the conviction, is so insufficient in probative value and force that it can be said as a matter of law…”
State v. Richard Joseph Jacobson (Wis. Ct. App. 2023). “§ 345.45 (stating the applicable burden of proof).”
Columbia Cnty. v. Carter Ray Smits (Wis. Ct. App. 2023). “§ 345.45 (standard of proof for conviction of a violation of a traffic regulation is clear and convincing evidence).”
— Wis. Stat. § 345.45(1) — 1 case
State v. Kiper, 532 N.W.2d 698 (Wis. 1995). “In 1992, Wanie was convicted, pursuant to § 345.45(1) of the Green Bay Code of Ordinances, of "permitting [an] unauthorized minor to drive.”
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