Wisconsin Statutes
Wis. Stat. § 803.045 (2026)
Actions to satisfy spousal obligations
✓ current as of July 2026
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803.045(1)(1) Except as provided in sub. (2), when a creditor commences an action on an obligation described in s. 766.55 (2), the creditor may proceed against the obligated spouse, the incurring spouse or both spouses.
803.045(2)(2) In an action on an obligation described in s. 766.55 (2) (a) or (b), a creditor may proceed against the spouse who is not the obligated spouse or the incurring spouse if the creditor cannot obtain jurisdiction in the action over the obligated spouse or the incurring spouse.
803.045(3)(3) After obtaining a judgment, a creditor may proceed against either or both spouses to reach marital property available for satisfaction of the judgment.
803.045(4)(4) This section does not affect the property available under s. 766.55 (2) to satisfy the obligation.
Notes of Decisions
Cited in 10
cases (1 in the last 5 years), 1994–2025 · leading case: Crown Castle USA, Inc. v. Orion Constr. Grp., LLC, 2012 WI 29 (Wis. 2012).
Crown Castle USA, Inc. v. Orion Constr. Grp., LLC, 2012 WI 29 (Wis. 2012). “Without examining the spouse of the judgment debtor, the judgment creditor would lack the information needed to proceed against the spouse under Wis. Stat. § 803.045 to reach marital property.”
Kurt Van Engel Comm'n Co., Inc. v. Zingale, 2005 WI App 82 (Wis. Ct. App. 2005). “As Van Engel Commission points out, however, Wis. Stat. § 803.045 (2) specifically permits this action against Mrs.”
Courtyard Condo. Ass'n, Inc. v. Draper, 2001 WI App 115 (Wis. Ct. App. 2001). “The judgment creditor's right to proceed to collect a judgment from the spouse of the judgment debtor is found in Wis. Stat. § 803.045 (3), "[a]fter obtaining a judgment, a creditor may proceed against either or both spouses to reach marital property available, for satisfaction…”
The Journal Sentinel, Inc. v. Schultz, 2001 WI App 260 (Wis. Ct. App. 2001). “1 (1991), John contends that both Wis. Stat. §§ 803.045 (3) and 766.55(4m) are unconstitutional.”
In Re Marriage of Curda-derickson v. Derickson, 2003 WI App 167 (Wis. Ct. App. 2003). “" Therefore, the case differs from a usual creditor's action against a spouse to reach his or her property to satisfy a debt, for example, a creditor's action to garnish a spouse's wages pursuant to Wis. Stat. § 803.045 . However, because the Sokaogon "became a creditor as a…”
Orlando Residence, Ltd. v. GP CREDIT CO., LLC, 553 F.3d 550 (7th Cir. 2009). “As part of its efforts to collect its judgment, Orlando brought a suit in a Wisconsin state court to establish that property that Mrs.”
St. Marys Hosp. Med. Ctr. v. Brody, 519 N.W.2d 706 (Wis. Ct. App. 1994). “The dissent discusses § 803.045, STATS. Nothing in § 803.045, imposes a liability against either spouse under § 766.”
St. Marys Hosp. Med. Ctr. v. Brody, 519 N.W.2d 706 (Wis. Ct. App. 1994). “The dissent discusses §803.045, STATS. Nothing in §803.045, imposes a liability against either spouse under §766.”
Eric L. Bizeau (Bankr. W.D. Wis. 2025). “” Wis. Stat. § 803.045 . That is, one spouse can be sued for obligations of the other, but only if the purpose is to reach marital property available under Wis.”
Susan Nelson v. Orlando Residence, Ltd (7th Cir. 2009). “As part of its efforts to collect its judgment, Orlando brought a suit in a Wiscon- sin state court to establish that property that Mrs.”
— Wis. Stat. § 803.045(1) — 2 cases
St. Marys Hosp. Med. Ctr. v. Brody, 519 N.W.2d 706 (Wis. Ct. App. 1994). “The dissent discusses § 803.045, STATS. Nothing in § 803.045, imposes a liability against either spouse under § 766.”
St. Marys Hosp. Med. Ctr. v. Brody, 519 N.W.2d 706 (Wis. Ct. App. 1994). “The dissent discusses §803.045, STATS. Nothing in §803.045, imposes a liability against either spouse under §766.”
— Wis. Stat. § 803.045(2) — 1 case
Kurt Van Engel Comm'n Co., Inc. v. Zingale, 2005 WI App 82 (Wis. Ct. App. 2005). “As Van Engel Commission points out, however, Wis. Stat. § 803.045 (2) specifically permits this action against Mrs.”
— Wis. Stat. § 803.045(3) — 5 cases
Crown Castle USA, Inc. v. Orion Constr. Grp., LLC, 2012 WI 29 (Wis. 2012). “Without examining the spouse of the judgment debtor, the judgment creditor would lack the information needed to proceed against the spouse under Wis. Stat. § 803.045 to reach marital property.”
Kurt Van Engel Comm'n Co., Inc. v. Zingale, 2005 WI App 82 (Wis. Ct. App. 2005). “As Van Engel Commission points out, however, Wis. Stat. § 803.045 (2) specifically permits this action against Mrs.”
The Journal Sentinel, Inc. v. Schultz, 2001 WI App 260 (Wis. Ct. App. 2001). “1 (1991), John contends that both Wis. Stat. §§ 803.045 (3) and 766.55(4m) are unconstitutional.”
St. Marys Hosp. Med. Ctr. v. Brody, 519 N.W.2d 706 (Wis. Ct. App. 1994). “The dissent discusses § 803.045, STATS. Nothing in § 803.045, imposes a liability against either spouse under § 766.”
St. Marys Hosp. Med. Ctr. v. Brody, 519 N.W.2d 706 (Wis. Ct. App. 1994). “The dissent discusses §803.045, STATS. Nothing in §803.045, imposes a liability against either spouse under §766.”
— Wis. Stat. § 803.045(4) — 3 cases
Kurt Van Engel Comm'n Co., Inc. v. Zingale, 2005 WI App 82 (Wis. Ct. App. 2005). “As Van Engel Commission points out, however, Wis. Stat. § 803.045 (2) specifically permits this action against Mrs.”
St. Marys Hosp. Med. Ctr. v. Brody, 519 N.W.2d 706 (Wis. Ct. App. 1994). “The dissent discusses § 803.045, STATS. Nothing in § 803.045, imposes a liability against either spouse under § 766.”
St. Marys Hosp. Med. Ctr. v. Brody, 519 N.W.2d 706 (Wis. Ct. App. 1994). “The dissent discusses §803.045, STATS. Nothing in §803.045, imposes a liability against either spouse under §766.”
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