Wisconsin Statutes

Wis. Stat. § 785.04 (2026)

Sanctions authorized

✓ current as of July 2026
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785.04785.04Sanctions authorized.
785.04(1)(1)Remedial sanction. A court may impose one or more of the following remedial sanctions:
785.04(1)(a)(a) Payment of a sum of money sufficient to compensate a party for a loss or injury suffered by the party as the result of a contempt of court.
785.04(1)(b)(b) Imprisonment if the contempt of court is of a type included in s. 785.01 (1) (b), (bm), (c) or (d). The imprisonment may extend only so long as the person is committing the contempt of court or 6 months, whichever is the shorter period.
785.04(1)(c)(c) A forfeiture not to exceed $2,000 for each day the contempt of court continues.
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785.04(1)(d)(d) An order designed to ensure compliance with a prior order of the court.
785.04(1)(e)(e) A sanction other than the sanctions specified in pars. (a) to (d) if it expressly finds that those sanctions would be ineffectual to terminate a continuing contempt of court.
785.04(2)(2)Punitive sanction.
785.04(2)(a)(a) Nonsummary procedure. A court, after a finding of contempt of court in a nonsummary procedure under s. 785.03 (1) (b), may impose for each separate contempt of court a fine of not more than $5,000 or imprisonment in the county jail for not more than one year or both.
785.04(2)(b)(b) Summary procedure. A court, after a finding of contempt of court in a summary procedure under s. 785.03 (2), may impose for each separate contempt of court a fine of not more than $500 or imprisonment in the county jail for not more than 30 days or both.
785.04(3)(3)Past conduct. A punitive sanction may be imposed for past conduct which was a contempt of court even though similar present conduct is a continuing contempt of court.
785.04 HistoryHistory: 1979 c. 257; 1993 a. 78.
785.04 AnnotationA court may award attorney fees and other litigation costs under sub. (1) (a). Town of Seymour v. City of Eau Claire, 112 Wis. 2d 313, 332 N.W.2d 821 (Ct. App. 1983).
785.04 AnnotationPurge conditions must be within the power of the contemnor and must be reasonably related to the cause or nature of the contempt. Larsen v. Larsen, 159 Wis. 2d 672, 465 N.W.2d 225 (Ct. App. 1990).
Notes of Decisions
Cited in 58 cases (15 in the last 5 years), 1983–2026 · leading case: Christensen v. Sullivan, 2009 WI 87 (Wis. 2009).
Christensen v. Sullivan, 2009 WI 87 (Wis. 2009). · cites it 150× “See Wis. Stat. § 785.04 (1)(a). Specifically, the plaintiff class postulates the following: Chapter 785, when read as a whole and in light of its legislative intent, history and purpose, gives the trial court discretion to impose remedial sanctions for any contempt of court that…”
Frisch v. Henrichs, 2007 WI 102 (Wis. 2007). · cites it 20× “" Wis. Stat. § 785.04 (1)(a), (b), and (c).”
Evans v. Luebke, 2003 WI App 207 (Wis. Ct. App. 2003). · cites it 18× “03 (l)(a), which establishes a procedure for the "nonsummary" imposition of remedial sanctions, and under Wis. Stat. § 785.04 (1) which specifies allowable remedial sanctions.”
City of Milwaukee v. Washington, 2007 WI 104 (Wis. 2007). · cites it 25× “Second, the court of appeals concluded that Wis. Stat. § 785.04 (1), the remedial contempt statute, provided the circuit court with an alternate basis to confine Washington to the CJF.”
Christensen v. Sullivan, 2008 WI App 18 (Wis. Ct. App. 2008). · cites it 37× “" Use of the past tense in the statute plainly authorizes payment for injuries that occurred in the past. The legislature apparently recognized that bringing a party into compliance with a court order did not necessarily cure the harm the victim of the noncompliance had already…”
Lassa v. Rongstad, 2006 WI 105 (Wis. 2006). · cites it 6× “As the circuit court has dismissed the underlying claim with prejudice, any relevance regarding First Amendment concerns would be now limited to the question of whether the circuit court should assess attorneys' fees against Rongstad, as opposed to whether the circuit court…”
City of Milwaukee v. Washington, 2006 WI App 99 (Wis. Ct. App. 2006). · cites it 18× “Although the trial court specifically struck all references to contempt in the proposed order before *272 it signed the order, we also address Washington's contention that confining her for more than six months is prohibited by Wis. Stat. § 785.04 (l)(b). ¶ 17. Both parties and…”
In Re Marriage of Benn v. Benn, 602 N.W.2d 65 (Wis. Ct. App. 1999). · cites it 6× “And finally, the circuit court's award of attorney fees under § 785.04 is a discretionary act. See Ably v.”
In Re Washington, 2007 WI 104 (Wis. 2007). · cites it 25× “Second, the court of appeals concluded that Wis. Stat. § 785.04 (1), the remedial contempt statute, provided the circuit court with an alternate basis to confine Washington to the CJF.”
Town of Seymour v. City of Eau Claire, 332 N.W.2d 821 (Wis. Ct. App. 1983). · cites it 5× “Additionally, the record indicates that the city’s construction of the transfer station was still possible. A consultant on transfer systems testified that the city could build the transfer station for $300,000 to $400,000.”
State v. Stewart, 916 N.W.2d 188 (Wis. Ct. App. 2018). · cites it 2× “The trial court stated that it did so pursuant to a Department of Corrections letter dated June 10, 2016, and Wis. Stat. § 785.04 (2)(a). The order commuting that sentence did not affect the sentences imposed on the identity theft charges and is not at issue here.”
State v. Gonzalez, 493 N.W.2d 410 (Wis. Ct. App. 1992). · cites it 9× “Thus, such acts may only be punished under the provisions of sec. 785.04, Stats. The state asserts that the term reflects the legislature's intent that the sec.”
— Wis. Stat. § 785.04(1) — 17 cases
Town of Seymour v. City of Eau Claire, 332 N.W.2d 821 (Wis. Ct. App. 1983). “Additionally, the record indicates that the city’s construction of the transfer station was still possible. A consultant on transfer systems testified that the city could build the transfer station for $300,000 to $400,000.”
Christensen v. Sullivan, 2009 WI 87 (Wis. 2009). “See Wis. Stat. § 785.04 (1)(a). Specifically, the plaintiff class postulates the following: Chapter 785, when read as a whole and in light of its legislative intent, history and purpose, gives the trial court discretion to impose remedial sanctions for any contempt of court that…”
Evans v. Luebke, 2003 WI App 207 (Wis. Ct. App. 2003). “03 (l)(a), which establishes a procedure for the "nonsummary" imposition of remedial sanctions, and under Wis. Stat. § 785.04 (1) which specifies allowable remedial sanctions.”
City of Milwaukee v. Washington, 2007 WI 104 (Wis. 2007). “Second, the court of appeals concluded that Wis. Stat. § 785.04 (1), the remedial contempt statute, provided the circuit court with an alternate basis to confine Washington to the CJF.”
In Re Washington, 2007 WI 104 (Wis. 2007). “Second, the court of appeals concluded that Wis. Stat. § 785.04 (1), the remedial contempt statute, provided the circuit court with an alternate basis to confine Washington to the CJF.”
— Wis. Stat. § 785.04(1)(a) — 12 cases
Christensen v. Sullivan, 2009 WI 87 (Wis. 2009). “See Wis. Stat. § 785.04 (1)(a). Specifically, the plaintiff class postulates the following: Chapter 785, when read as a whole and in light of its legislative intent, history and purpose, gives the trial court discretion to impose remedial sanctions for any contempt of court that…”
Christensen v. Sullivan, 2008 WI App 18 (Wis. Ct. App. 2008). “" Use of the past tense in the statute plainly authorizes payment for injuries that occurred in the past. The legislature apparently recognized that bringing a party into compliance with a court order did not necessarily cure the harm the victim of the noncompliance had already…”
In Re Marriage of Frisch v. Henrichs, 2006 WI App 64 (Wis. Ct. App. 2006).
Am. Oversight v. Robin Vos (Wis. Ct. App. 2024).
— Wis. Stat. § 785.04(1)(b) — 9 cases
Frisch v. Henrichs, 2007 WI 102 (Wis. 2007). “" Wis. Stat. § 785.04 (1)(a), (b), and (c).”
State ex rel. Larsen v. Larsen, 478 N.W.2d 18 (Wis. 1992).
Diane K. J. v. James L. J., 539 N.W.2d 703 (Wis. Ct. App. 1995).
City of Milwaukee v. Washington, 2006 WI App 99 (Wis. Ct. App. 2006). “Although the trial court specifically struck all references to contempt in the proposed order before *272 it signed the order, we also address Washington's contention that confining her for more than six months is prohibited by Wis. Stat. § 785.04 (l)(b). ¶ 17. Both parties and…”
In Re Washington, 2007 WI 104 (Wis. 2007). “Second, the court of appeals concluded that Wis. Stat. § 785.04 (1), the remedial contempt statute, provided the circuit court with an alternate basis to confine Washington to the CJF.”
— Wis. Stat. § 785.04(1)(c) — 6 cases
Lassa v. Rongstad, 2006 WI 105 (Wis. 2006). “As the circuit court has dismissed the underlying claim with prejudice, any relevance regarding First Amendment concerns would be now limited to the question of whether the circuit court should assess attorneys' fees against Rongstad, as opposed to whether the circuit court…”
Christensen v. Sullivan, 2009 WI 87 (Wis. 2009). “See Wis. Stat. § 785.04 (1)(a). Specifically, the plaintiff class postulates the following: Chapter 785, when read as a whole and in light of its legislative intent, history and purpose, gives the trial court discretion to impose remedial sanctions for any contempt of court that…”
Christensen v. Sullivan, 2008 WI App 18 (Wis. Ct. App. 2008). “" Use of the past tense in the statute plainly authorizes payment for injuries that occurred in the past. The legislature apparently recognized that bringing a party into compliance with a court order did not necessarily cure the harm the victim of the noncompliance had already…”
Ervin Peters v. Clarence Peters (Wis. Ct. App. 2022).
Ted B. Vallejos v. Gary Kramschuster (Wis. Ct. App. 2020).
— Wis. Stat. § 785.04(1)(d) — 3 cases
Christensen v. Sullivan, 2009 WI 87 (Wis. 2009). “See Wis. Stat. § 785.04 (1)(a). Specifically, the plaintiff class postulates the following: Chapter 785, when read as a whole and in light of its legislative intent, history and purpose, gives the trial court discretion to impose remedial sanctions for any contempt of court that…”
Nicole Huiras v. Nathan Huiras (Wis. Ct. App. 2023).
In Re Washington, 2006 WI App 99 (Wis. Ct. App. 2006).
— Wis. Stat. § 785.04(1)(e) — 4 cases
City of Milwaukee v. Washington, 2006 WI App 99 (Wis. Ct. App. 2006). “Although the trial court specifically struck all references to contempt in the proposed order before *272 it signed the order, we also address Washington's contention that confining her for more than six months is prohibited by Wis. Stat. § 785.04 (l)(b). ¶ 17. Both parties and…”
Leonard Pozner v. James Fetzer (Wis. Ct. App. 2021).
In Re Washington, 2006 WI App 99 (Wis. Ct. App. 2006).
— Wis. Stat. § 785.04(2) — 4 cases
State v. Chinavare, 518 N.W.2d 772 (Wis. Ct. App. 1994).
Currie v. Schwalbach, 390 N.W.2d 575 (Wis. Ct. App. 1986).
Findings of Contempt in Wisconsin v. Dewerth, 390 N.W.2d 575 (Wis. Ct. App. 1986).
— Wis. Stat. § 785.04(2)(a) — 4 cases
State v. Carpenter, 508 N.W.2d 69 (Wis. Ct. App. 1993).
State v. Chinavare, 518 N.W.2d 772 (Wis. Ct. App. 1994).
Off. of Lawyer Reg. v. Michael D. Petersen, 2017 WI 102 (Wis. 2017).
— Wis. Stat. § 785.04(2)(b) — 4 cases
State v. Gonzalez, 493 N.W.2d 410 (Wis. Ct. App. 1992). “Thus, such acts may only be punished under the provisions of sec. 785.04, Stats. The state asserts that the term reflects the legislature's intent that the sec.”
Contempt in State v. Dewerth, 407 N.W.2d 862 (Wis. 1987).
State v. Carpenter, 508 N.W.2d 69 (Wis. Ct. App. 1993).
— Wis. Stat. § 785.04(l)(a) — 4 cases
Christensen v. Sullivan, 2009 WI 87 (Wis. 2009). “See Wis. Stat. § 785.04 (1)(a). Specifically, the plaintiff class postulates the following: Chapter 785, when read as a whole and in light of its legislative intent, history and purpose, gives the trial court discretion to impose remedial sanctions for any contempt of court that…”
In Re Marriage of Benn v. Benn, 602 N.W.2d 65 (Wis. Ct. App. 1999). “And finally, the circuit court's award of attorney fees under § 785.04 is a discretionary act. See Ably v.”
Evans v. Luebke, 2003 WI App 207 (Wis. Ct. App. 2003). “03 (l)(a), which establishes a procedure for the "nonsummary" imposition of remedial sanctions, and under Wis. Stat. § 785.04 (1) which specifies allowable remedial sanctions.”
Christensen v. Sullivan, 2008 WI App 18 (Wis. Ct. App. 2008). “" Use of the past tense in the statute plainly authorizes payment for injuries that occurred in the past. The legislature apparently recognized that bringing a party into compliance with a court order did not necessarily cure the harm the victim of the noncompliance had already…”
— Wis. Stat. § 785.04(l)(b) — 5 cases
Frisch v. Henrichs, 2007 WI 102 (Wis. 2007). “" Wis. Stat. § 785.04 (1)(a), (b), and (c).”
State ex rel. Larsen v. Larsen, 478 N.W.2d 18 (Wis. 1992).
City of Milwaukee v. Washington, 2007 WI 104 (Wis. 2007). “Second, the court of appeals concluded that Wis. Stat. § 785.04 (1), the remedial contempt statute, provided the circuit court with an alternate basis to confine Washington to the CJF.”
State Ex Rel. Larsen v. Larsen, 465 N.W.2d 225 (Wis. Ct. App. 1990).
— Wis. Stat. § 785.04(l)(c) — 4 cases
Evans v. Luebke, 2003 WI App 207 (Wis. Ct. App. 2003). “03 (l)(a), which establishes a procedure for the "nonsummary" imposition of remedial sanctions, and under Wis. Stat. § 785.04 (1) which specifies allowable remedial sanctions.”
Lassa v. Rongstad, 2006 WI 105 (Wis. 2006). “As the circuit court has dismissed the underlying claim with prejudice, any relevance regarding First Amendment concerns would be now limited to the question of whether the circuit court should assess attorneys' fees against Rongstad, as opposed to whether the circuit court…”
Christensen v. Sullivan, 2009 WI 87 (Wis. 2009). “See Wis. Stat. § 785.04 (1)(a). Specifically, the plaintiff class postulates the following: Chapter 785, when read as a whole and in light of its legislative intent, history and purpose, gives the trial court discretion to impose remedial sanctions for any contempt of court that…”
Christensen v. Sullivan, 2008 WI App 18 (Wis. Ct. App. 2008). “" Use of the past tense in the statute plainly authorizes payment for injuries that occurred in the past. The legislature apparently recognized that bringing a party into compliance with a court order did not necessarily cure the harm the victim of the noncompliance had already…”
— Wis. Stat. § 785.04(l)(d) — 2 cases
Christensen v. Sullivan, 2009 WI 87 (Wis. 2009). “See Wis. Stat. § 785.04 (1)(a). Specifically, the plaintiff class postulates the following: Chapter 785, when read as a whole and in light of its legislative intent, history and purpose, gives the trial court discretion to impose remedial sanctions for any contempt of court that…”
Carney v. CNH Health & Welfare Plan, 2007 WI App 205 (Wis. Ct. App. 2007).
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.