Wis. Stat. » CHAPTER 799 — PROCEDURE IN SMALL CLAIMS ACTIONS
Wisconsin Statutes

Wis. Stat. § 799.29 (2026)

Default judgments

✓ current as of July 2026
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799.29799.29 Default judgments.
799.29(1)(1) Motion to reopen.
799.29(1)(a)(a) There shall be no appeal from default judgments, but the trial court may, by order, reopen default judgments upon notice and motion or petition duly made and good cause shown.
799.29(1)(b)(b) In ordinance violation cases, the notice of motion must be made within 20 days after entry of judgment. In ordinance violation cases, default judgments for purposes of this section include pleas of guilty, no contest and forfeitures of deposit.
799.29(1)(c)(c) In other actions under this chapter, the notice of motion must be made within 12 months after entry of judgment unless venue was improper under s. 799.11. The court shall order the reopening of a default judgment in an action where venue was improper upon motion or petition duly made within one year after the entry of judgment.
799.29(2)(2) Stipulations. The court or judge having trial jurisdiction to recover a forfeiture may, with or without notice, for good cause shown by affidavit and upon just terms, within 30 days after the stipulation has been entered into, relieve any person from the stipulation or any order, judgment or conviction entered or made thereon. Where the stipulation was made without appearance in or having been filed in court, the court or l judge may order a written complaint to be filed and set the matter for trial. The stipulation or a copy shall, in such cases, be filed with the court or judge and costs and fees shall be taxed as provided by law.
799.29 HistoryHistory: 1979 c. 32 s. 66; 1979 c. 110 s. 60 (6); Stats. 1979 s. 799.29; 1983 a. 228; 1985 a. 332; 1987 a. 208; 2003 a. 138; 2019 a. 70.
799.29 NoteJudicial Council Note, 1983: Sub. (1) (c) liberalizes the time limit for reopening default judgments entered in improperly venued actions. This remedy supplements the court’s authority under s. 799.11 (3) to correct venue on its own motion. [Bill 324-S]
799.29 AnnotationSub. (1) provides the exclusive procedure for reopening a default judgment in small claims proceedings. King v. Moore, 95 Wis. 2d 686, 291 N.W.2d 304 (Ct. App. 1980).
Notes of Decisions
Cited in 15 cases (5 in the last 5 years), 1983–2026 · leading case: Mercado v. GE Money Bank, 2009 WI App 73 (Wis. Ct. App. 2009).
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Mercado v. GE Money Bank, 2009 WI App 73 (Wis. Ct. App. 2009). · cites it 18× “We conclude: (1) Mercado and Terry's failure to follow the statutory procedure set forth in Wis. Stat. § 799.29 precludes them from collaterally attacking the default judgments entered against them here; and (2) the default judgments are not void.”
Gen. Tel. Co. of Wi, Inc. v. a Corp., 433 N.W.2d 264 (Wis. Ct. App. 1988). · cites it 4× “General Telephone contends that no appeal may be taken from the February 15, 1988 judgment since sec. 799.29(1), Stats., provides, "There shall be no appeal from default judgments, but the trial court may, by order, reopen default judgments upon notice and motion or petition…”
Radmer v. Edell, 395 N.W.2d 629 (Wis. Ct. App. 1986). · cites it 2× “Thereafter, Radmer moved the circuit court to vacate the commissioner’s dismissal order pursuant to *412 sec. 799.29, Stats. This statute permits the reopening of default judgments upon “good cause shown.”
Mock v. Czemierys, 336 N.W.2d 188 (Wis. Ct. App. 1983). “07, Stats, (relief from judgment) , inapplicable to small claims cases in view of contrary language in sec. 799.29, Stats. The court emphasized the legislative intent behind the distinction, that is, small claims practice is summary and designed to be terminated more readily…”
Nehls v. Nehls, 2012 WI App 85 (Wis. Ct. App. 2012). · cites it 2× “shall be heard by the supervising mu *508 nicipal judge"); Wis. Stat. § 799.29 (l)(a) (providing that in small claims actions "[t]here shall be no appeal from default judgments").”
Mandujano v. Mendoza, 918 N.W.2d 644 (Wis. Ct. App. 2018). · cites it 9× “§ 799.29, or "good cause." Despite the confusion, the appeal in this case can only be from the denial of the motion to reopen.”
Martindale Pinnacle Constr. v. John Pulley (Wis. Ct. App. 2020). · cites it 7× “§ 799.29(1). This appeal follows. DISCUSSION ¶6 A court commissioner may dismiss a small claims action for plaintiff’s failure to appear on the date set for the return date or trial.”
Capital One Bank (Usa), N.A. v. McCune, 926 N.W.2d 511 (Wis. Ct. App. 2019). · cites it 6× “29(1), rather than Wis. Stat. § 799.29 (1) governed reopening default judgments in small claims actions.”
Port Washington State Bank, A Wisconsin Banking Corp. v. Roxanne D. Hendon (Wis. Ct. App. 2026). · cites it 5× “§ 799.29 such that they would warrant the requested relief.”
Forsythe Fin., LLC v. Jerome J. Casimir (Wis. Ct. App. 2024). · cites it 3× “§ 799.29(1)(a). 2 No. 2023AP2025 ¶4 The publication summons warned that if Casimir did “not attend the hearing, the court may enter a judgment against [him].”
Cmty. First Credit Union v. Jason Michael Mathe (Wis. Ct. App. 2026). · cites it 3× “§ 799.29 (“There shall be no appeal from default judgments, but the trial court may, by order, reopen default judgments upon notice and motion or petition duly made and good cause shown.”
Haggett v. Voboril, 921 N.W.2d 527 (Wis. Ct. App. 2018). · cites it 2× “§ 799.29(1)(a) provides that, in small claims actions, "[t]here shall be no appeal from default judgments, but the trial court may, by order, reopen default judgments upon notice and motion or petition duly made and good cause shown.”
Show all 15 citing cases →
— Wis. Stat. § 799.29(1) — 5 cases
Gen. Tel. Co. of Wi, Inc. v. a Corp., 433 N.W.2d 264 (Wis. Ct. App. 1988). “General Telephone contends that no appeal may be taken from the February 15, 1988 judgment since sec. 799.29(1), Stats., provides, "There shall be no appeal from default judgments, but the trial court may, by order, reopen default judgments upon notice and motion or petition…”
Mandujano v. Mendoza, 918 N.W.2d 644 (Wis. Ct. App. 2018). “§ 799.29, or "good cause." Despite the confusion, the appeal in this case can only be from the denial of the motion to reopen.”
Martindale Pinnacle Constr. v. John Pulley (Wis. Ct. App. 2020). “§ 799.29(1). This appeal follows. DISCUSSION ¶6 A court commissioner may dismiss a small claims action for plaintiff’s failure to appear on the date set for the return date or trial.”
Capital One Bank (Usa), N.A. v. McCune, 926 N.W.2d 511 (Wis. Ct. App. 2019). “29(1), rather than Wis. Stat. § 799.29 (1) governed reopening default judgments in small claims actions.”
Cmty. First Credit Union v. Jason Michael Mathe (Wis. Ct. App. 2026). “§ 799.29 (“There shall be no appeal from default judgments, but the trial court may, by order, reopen default judgments upon notice and motion or petition duly made and good cause shown.”
— Wis. Stat. § 799.29(1)(a) — 10 cases
Mandujano v. Mendoza, 918 N.W.2d 644 (Wis. Ct. App. 2018). “§ 799.29, or "good cause." Despite the confusion, the appeal in this case can only be from the denial of the motion to reopen.”
Martindale Pinnacle Constr. v. John Pulley (Wis. Ct. App. 2020). “§ 799.29(1). This appeal follows. DISCUSSION ¶6 A court commissioner may dismiss a small claims action for plaintiff’s failure to appear on the date set for the return date or trial.”
Forsythe Fin., LLC v. Jerome J. Casimir (Wis. Ct. App. 2024). “§ 799.29(1)(a). 2 No. 2023AP2025 ¶4 The publication summons warned that if Casimir did “not attend the hearing, the court may enter a judgment against [him].”
Haggett v. Voboril, 921 N.W.2d 527 (Wis. Ct. App. 2018). “§ 799.29(1)(a) provides that, in small claims actions, "[t]here shall be no appeal from default judgments, but the trial court may, by order, reopen default judgments upon notice and motion or petition duly made and good cause shown.”
Capital One Bank (Usa), N.A. v. McCune, 926 N.W.2d 511 (Wis. Ct. App. 2019). “29(1), rather than Wis. Stat. § 799.29 (1) governed reopening default judgments in small claims actions.”
— Wis. Stat. § 799.29(l)(a) — 2 cases
Mercado v. GE Money Bank, 2009 WI App 73 (Wis. Ct. App. 2009). “We conclude: (1) Mercado and Terry's failure to follow the statutory procedure set forth in Wis. Stat. § 799.29 precludes them from collaterally attacking the default judgments entered against them here; and (2) the default judgments are not void.”
Radmer v. Edell, 395 N.W.2d 629 (Wis. Ct. App. 1986). “Thereafter, Radmer moved the circuit court to vacate the commissioner’s dismissal order pursuant to *412 sec. 799.29, Stats. This statute permits the reopening of default judgments upon “good cause shown.”
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.