Wis. Stat. » CHAPTER 452 — REAL ESTATE PRACTICE
Wisconsin Statutes

Wis. Stat. § 452.20 (2026)

Limitation on actions for commissions

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452.20452.20 Limitation on actions for commissions. No person engaged in the business or acting in the capacity of a broker or salesperson within this state may bring or maintain an action in the courts of this state for the collection of a commission or compensation for the performance of any act mentioned in this chapter without alleging and proving that he or she was a duly licensed broker or salesperson at the time the alleged cause of action arose.
452.20 HistoryHistory: 1981 c. 94; 1987 a. 399; 1989 a. 56; 2015 a. 258.
452.20 AnnotationA foreign corporation that contracts to sell a radio station without being licensed in this state cannot sue for its commission. The licensing requirement is not an unlawful burden on interstate commerce. Chapman Co. v. Service Broadcasting Corp., 52 Wis. 2d 32, 187 N.W.2d 794 (1971).
452.20 AnnotationThe prohibition against paying a commission to an unlicensed person acting as a broker is absolute and not conditioned on the innocence or lack of sophistication of the other contracting parties. Because a contract for a commission with a person not licensed as a broker is void from its inception, estoppel is not available to avoid the effect of the statute. Greenlee v. Rainbow Auction/Realty Co., 202 Wis. 2d 653, 553 N.W.2d 257 (Ct. App. 1996), 95-1463.
452.20 AnnotationThis section was not applicable since the broker, acting as the owner’s agent, was not attempting to negotiate the lease when conferring with the broker’s alleged principal in Wisconsin and therefore was not acting in the capacity of a broker in Wisconsin. The negotiation of the lease occurred when the broker met and conferred with the prospective lessee either in Illinois or Tennessee. Paulson v. Shapiro, 490 F.2d 1 (1973).
Notes of Decisions
Cited in 8 cases, 1992–2012 · leading case: Greenlee v. Rainbow Auction/Realty Co., Inc., 553 N.W.2d 257 (Wis. Ct. App. 1996).
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Greenlee v. Rainbow Auction/Realty Co., Inc., 553 N.W.2d 257 (Wis. Ct. App. 1996). · cites it 23× “Although the verdict did not contain any questions concerning § 452.20, Stats., there was an instruction on the statute.”
Bertha v. Remy Int'l Inc., 414 F. Supp. 2d 869 (E.D. Wis. 2006). · cites it 13× “” Remy International contends that Bertha’s claims are legally precluded by Wis. Stat. § 452.20 because Bertha is not a licensed broker.”
Badger III Ltd. P'ship v. Howard, Needles, Tammen & Bergendoff, 539 N.W.2d 904 (Wis. Ct. App. 1995). · cites it 4× “4 Section 452.20, Stats., augments the enforcement of § 452.”
Olsen v. Celano, 600 N.E.2d 1257 (Ill. App. Ct. 2d Dist. 1992). · cites it 2× “) And: “No person engaged in the business or acting in the capacity of a broker, salesperson or time-share salesperson within this state may bring or maintain an action in the courts of this state for the collection of a commission or compensation for the performance of any act…”
Hernandez v. BNG Mgmt. Ltd. P'ship, 2012 WI App 65, 815 N.W.2d 725. · cites it 3× “See Wis. Stat. §§ 452.20 , 452.17(1). 2 Thus, Wisconsin courts have routinely upheld the inability of a non-licensed real-estate broker to recover commissions in our courts because a "contract for a commission *733 for [real-estate brokerage] activities is void from its…”
Schlueter v. LATEK, 821 F. Supp. 2d 1079 (E.D. Wis. 2011). · cites it 2× “Wis. Stat. § 452.20 . Thus, if Latek acted as a broker and Sehlueter refused to pay his fee, Latek could not use the courts to obtain payment.”
Kadlec v. Kadlec, 2004 WI App 84, 679 N.W.2d 914. · cites it 3× “§ 452.20 provides: No person engaged in the business or acting in the capacity of a broker, salesperson or time-share salesperson within this state may bring or maintain an action in the courts of this state for the collection of a commission or compensation for the performance…”
Greenlee v. Rainbow Auction/Realty Co., Inc., 582 N.W.2d 93 (Wis. Ct. App. 1998). “In a prior appeal, we determined that § 452.20, STATS., barred Greenlee's action because he was attempting to enforce an illegal contract by seeking a commission on the sale of real estate without a realtor's license.”
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.