Wisconsin Statutes
Wis. Stat. § 631.15 (2026)
Contract rights under noncomplying policies
✓ current as of July 2026
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631.15(1)(1) Enforcement of policy terms. Except as otherwise specifically provided by statute, a policy is enforceable against the insurer according to its terms, even if it exceeds the authority of the insurer.
631.15(3m)(3m) Enforcement of statute and rule requirements. A policy that violates a statute or rule is enforceable against the insurer as if it conformed to the statute or rule.
631.15(4)(4) Reformation of contract. Upon written request of the policyholder or an insured whose rights under the policy are continuing and not transitory, an insurer shall reform and reissue its written policy to comply with the requirements of the law existing at the date of issue or last renewal of the policy.
631.15 AnnotationWhen underinsured motorist coverage in the amount of $25,000 was contracted for in violation of the requirement for $50,000 coverage under former s. 632.32 (4m) (d), 1995 stats., the higher level of coverage was read into the policy under sub. (3m), even though it was not reflected in the premium paid. Brunson v. Ward, 2001 WI 89, 245 Wis. 2d 163, 629 N.W.2d 140, 98-3002.
Notes of Decisions
Cited in 15
cases (1 in the last 5 years), 1997–2025 · leading case: Brunson v. Ward, 2001 WI 89 (Wis. 2001).
Brunson v. Ward, 2001 WI 89 (Wis. 2001). “See Wis. Stat. § 631.15 (3m). *173 ¶ 15. Progressive's policy accounts for the possibility that certain of its provisions might conflict with state statute, and the insurer agrees in any such instance to be bound by the requirements of statute (it could hardly do otherwise),…”
Stone v. Acuity, 2008 WI 30 (Wis. 2008). “IV ¶ 38 Having concluded that Acuity violated § 632.32(4m) by failing to provide *158 the Stones with notice of the availability of UIM coverage on their umbrella policy, there remains a question of the appropriate remedy for such a violation.”
Rebernick v. Wausau Gen. Ins., 2006 WI 27 (Wis. 2006). “Under Wis. Stat. § 631.15 (3m), an insurance policy "that violates a statute or rule is enforceable against the insurer as if it conformed to the statute or rule.”
Welin v. Am. Fam. Mut. Ins., 2006 WI 81 (Wis. 2006). “Under Wis. Stat. § 631.15 (3m), when an insurance policy violates a statutory provision, the remedy is to enforce the policy as though it conformed to the statutory requirement.”
Froedtert Mem'l Lutheran Hosp., Inc. v. Nat'l STATES Ins. Co.., 2009 WI 33 (Wis. 2009). “See Wis. Stat. § 631.15 (3m) ("A policy that violates a statute or rule is enforceable against the insurer as if it conformed to the statute or rule.”
LaCount Ex Rel. LaCount v. Gen. Cas. Co., 2006 WI 14 (Wis. 2006). “W 881 (1932); see Wis. Stat. § 631.15 (3m) ("A policy that violates a statute or rule is enforceable against the insurer as if it conformed to the statute or rule.”
Appleton Papers, Inc. v. Home Indem. Co., 2000 WI App 104 (Wis. Ct. App. 2000). “§631.15(1), even if the insurance commissioner had not approved the arbitration provision.”
Casper v. Am. Int'l South Ins., 2010 WI App 2 (Wis. Ct. App. 2009). “Wis. Stat. § 631.15 (4). The Caspers argue that Wearing was a permissive driver under the omnibus statute, and, therefore, the policy must be reformed to afford Wearing the same coverage Ryder would have received under the policy.”
Progressive N. Ins. v. Hall, 2006 WI 13 (Wis. 2006). “It notes that "[a]ny immaterial language in Progressive's 'other insurance' clause need not be 'invalidated.'" ¶ 38.”
Wisconsin Patients Comp. Fund v. St. Mary's Hosp. of Milwaukee, 561 N.W.2d 797 (Wis. Ct. App. 1997). “§ 631.15 (West 1995), explaining that "[t]his section deals with the 'private law' consequences of violation.”
Stone v. Acuity, a Mut. Ins., 2006 WI App 205 (Wis. Ct. App. 2006). “As the concurrence/dissent in Rebemick noted, Wis. Stat. § 631.15 (3m) provides that "[a] policy that violates a statute or rule is enforceable against the insurer as if it conformed to the statute or rule.”
Lexington Ins. v. Rugg & Knopp, Inc., 1 F. Supp. 2d 937 (E.D. Wis. 1998). “Wis. Stat. § 631.15 (3m). Sections 631.81(1) and 632.”
— Wis. Stat. § 631.15(1) — 1 case
Appleton Papers, Inc. v. Home Indem. Co., 2000 WI App 104 (Wis. Ct. App. 2000). “§631.15(1), even if the insurance commissioner had not approved the arbitration provision.”
— Wis. Stat. § 631.15(2) — 1 case
Wisconsin Patients Comp. Fund v. St. Mary's Hosp. of Milwaukee, 561 N.W.2d 797 (Wis. Ct. App. 1997). “§ 631.15 (West 1995), explaining that "[t]his section deals with the 'private law' consequences of violation.”
— Wis. Stat. § 631.15(3m) — 6 cases
Brunson v. Ward, 2001 WI 89 (Wis. 2001). “See Wis. Stat. § 631.15 (3m). *173 ¶ 15. Progressive's policy accounts for the possibility that certain of its provisions might conflict with state statute, and the insurer agrees in any such instance to be bound by the requirements of statute (it could hardly do otherwise),…”
Stone v. Acuity, 2008 WI 30 (Wis. 2008). “IV ¶ 38 Having concluded that Acuity violated § 632.32(4m) by failing to provide *158 the Stones with notice of the availability of UIM coverage on their umbrella policy, there remains a question of the appropriate remedy for such a violation.”
Rebernick v. Wausau Gen. Ins., 2006 WI 27 (Wis. 2006). “Under Wis. Stat. § 631.15 (3m), an insurance policy "that violates a statute or rule is enforceable against the insurer as if it conformed to the statute or rule.”
Appleton Papers, Inc. v. Home Indem. Co., 2000 WI App 104 (Wis. Ct. App. 2000). “§631.15(1), even if the insurance commissioner had not approved the arbitration provision.”
Distinguished Multiplying Bldgs. (D.M.B.), LLC v. Germantown Mut. Ins. Co. (Wis. Ct. App. 2025).
— Wis. Stat. § 631.15(4) — 2 cases
Casper v. Am. Int'l South Ins., 2010 WI App 2 (Wis. Ct. App. 2009). “Wis. Stat. § 631.15 (4). The Caspers argue that Wearing was a permissive driver under the omnibus statute, and, therefore, the policy must be reformed to afford Wearing the same coverage Ryder would have received under the policy.”
Stone v. Acuity, a Mut. Ins., 2006 WI App 205 (Wis. Ct. App. 2006). “As the concurrence/dissent in Rebemick noted, Wis. Stat. § 631.15 (3m) provides that "[a] policy that violates a statute or rule is enforceable against the insurer as if it conformed to the statute or rule.”
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