Wisconsin Statutes
Wis. Stat. § 806.19 (2026)
Satisfaction of judgments
✓ current as of July 2026
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806.19(1)(a)(a) A judgment may be satisfied in whole or in part or as to any judgment debtor by an instrument signed and acknowledged by the owner or, if no assignment has been filed, by the owner’s attorney of record, or by an acknowledgment of satisfaction, signed and entered on the judgment and lien docket in the county where first entered, with the date of entry, and witnessed by the clerk of circuit court. Every satisfaction of a part of a judgment or as to some of the judgment debtors shall state the amount paid on the judgment or for the release of the debtors, naming them.
806.19(1)(b)(b) No satisfaction by an attorney shall be conclusive upon the judgment creditor in respect to any person who has notice of revocation of the authority of such attorney, before any payment made thereon or before any purchase of property bound by such judgment has been effected.
806.19(1)(c)(c) On filing a duly executed satisfaction, the clerk of circuit court shall enter the satisfaction on the court record of the case and shall enter a statement of the substance of the satisfaction, including the amount paid, on the judgment and lien docket with the date of filing the satisfaction.
806.19(2)(2) When an execution is returned satisfied in whole or in part the judgment is considered satisfied to the extent of the amount so returned unless the return is vacated. The clerk of circuit court shall enter in the judgment and lien docket that the amount stated in the return has been collected.
806.19(3)(3) For the purpose of paying any money judgment, the debtor may deposit with the clerk of circuit court in which the judgment was entered the amount of liability on the judgment. The clerk of circuit court shall give the debtor a certificate showing the date and amount of the deposit and identifying the judgment. The clerk of circuit court shall immediately note on the judgment and lien docket the amount and date of the deposit. The debtor shall immediately give written notice to the owner of record of the judgment and to the owner’s attorney of record, personally, or by registered mail, to the last-known post-office address, stating the amount, date and purpose of the deposit, and that it is held subject to the order of the judgment owner. Ten days after giving the notice, the clerk of circuit court shall, upon filing proof of service, satisfy the judgment of record, unless the trial court otherwise orders. Acceptance by the owner of the sum deposited has the same legal consequences that payment direct by the debtor would have. Payment to the clerk shall include the fee prescribed in s. 814.61 (5).
806.19(4)(a)(a) Any person who has secured a discharge of a judgment debt in bankruptcy and any person interested in real property to which the judgment attaches may submit an application for an order of satisfaction of the judgment and an attached order of satisfaction to the clerk of the court in which the judgment was entered.
APPLICATION FOR ORDER OF SATISFACTION OF JUDGMENTS DUE TO DISCHARGE IN BANKRUPTCY
TO: Clerk of Circuit Court
....County
1. .... (Name of judgment debtor) has received an order of discharge of debts under the bankruptcy laws of the United States, a copy of which is attached, and .... (Name of judgment debtor or person interested in real property) applies for satisfaction of the following judgments:
.... (List of judgments by case name, case number, date and, if applicable, judgment and lien docket volume and page number.)
2. a. Copies of the schedules of debts as filed with the bankruptcy court showing each judgment creditor for each of the judgments described above are attached; or
b. Each judgment creditor for each of the judgments described above has been duly notified of the bankruptcy case in the following manner: ....(statement of form of notice).
3. The undersigned believes that each judgment listed above has been discharged in bankruptcy, and no inconsistent ruling has been made by, or is being requested by any party from, the bankruptcy court.
Dated this .... day of ...., ..... (year)
.... (Signature)
Judgment Debtor,
Person Interested
in Real Property
or Attorney for
Debtor or Person
Judgment Debtor,
Person Interested
in Real Property
or Attorney for
Debtor or Person
ORDER OF SATISFACTION
The clerk of circuit court is directed to indicate on the judgment and lien docket that each judgment described in the attached application has been satisfied.
Dated this .... day of ...., .... (year)
.... (Signature)
Circuit Judge
Circuit Judge
806.19(4)(bm)(bm) The copy of the order of discharge that is attached to the application shall be either a certified copy or a photocopy of the order in the form in which it was served on parties in interest by the bankruptcy court.
806.19(4)(c)(c) Any person submitting an application and attached proposed order shall serve a copy of the completed application and attached proposed order on each judgment creditor for each of the judgments described in the application within 5 business days after the date of submission.
806.19(4)(d)(d) Upon receipt of a completed application, the clerk shall submit the attached proposed order for signature by a judge after which the clerk shall satisfy of record each judgment described in the application. Upon satisfaction, a judgment shall cease to be a lien on any real property that the person discharged in bankruptcy owns or later acquires.
806.19 HistoryHistory: 1973 c. 211; Sup. Ct. Order, 67 Wis. 2d 585, 735 (1975); 1975 c. 218; 1981 c. 317; 1985 a. 137; 1987 a. 202; 1995 a. 224, 393; 1997 a. 250.
806.19 AnnotationNothing in sub. (4) requires that the order of satisfaction cover all debts discharged in bankruptcy. EPF Corp. v. Pfost, 210 Wis. 2d 79, 563 N.W.2d 905 (Ct. App. 1997), 96-0006.
806.19 AnnotationWhen a proper application is received by the clerk and submitted to the judge for signature, the only thing required for satisfaction of a judgment debt and cessation of an associated judgment lien under sub. (4) is that the underlying judgment has been discharged in bankruptcy. Failure to avoid the judgment lien in bankruptcy does not affect the operation of sub. (4). Sub. (4) is not in conflict with, and therefore not preempted by, federal bankruptcy law. Megal Development Corp. v. Shadof, 2005 WI 151, 286 Wis. 2d 105, 705 N.W.2d 645, 04-1594.
806.19 AnnotationIn bankruptcy proceedings, the lien of a judgment obtained before discharge was not extinguished by discharge and could be applied to the proceeds of the bankruptcy sale of the real estate to which the lien attached. Wisconsin statutes do not provide that the lien is automatically extinguished by the discharge in bankruptcy; rather, they require an application by the discharged bankrupt to the court in which the judgment was entered, and the entry by that court of an order of satisfaction. In re Tillman Produce Co., 396 F. Supp. 500 (1975).
Notes of Decisions
Cited in 18
cases (5 in the last 5 years), 1978–2024 · leading case: Megal Dev. Corp. v. Shadof, 2005 WI 151 (Wis. 2005).
Megal Dev. Corp. v. Shadof, 2005 WI 151 (Wis. 2005). “1 Defendants Craig and Susan Shadof (Shad-ofs) appeal an order of the circuit court denying their application for satisfaction of a judgment and a judgment lien under Wis. Stat. § 806.19 (4), where the underlying judgment had been discharged in bankruptcy.”
State Cent. Credit Union v. Bigus, 304 N.W.2d 148 (Wis. Ct. App. 1981). “” Further, Bigus’ interpretation is not true to the language of sec. 806.19(4), Stats., and, in effect, rewrites the last sentence to read: The entry of such order of satisfaction of judgment shall bar any other action in the courts of this state against such bankrupt person or…”
Repub. Bank of Chicago v. Lichosyt, 2007 WI App 150 (Wis. Ct. App. 2007). “91(2), [now Wis. Stat. § 806.19 (4)] because of the subsequent bankruptcy action on the part of [the vendee].”
Wiebke v. Richardson & Sons, Inc., 265 N.W.2d 571 (Wis. 1978). “1973, currently sec. 806.19(4), Stats. 5 The entry of satisfaction was not the result of a contract into which Wiebke entered voluntarily.”
In Re Spore, 105 B.R. 476 (Bankr. W.D. Wis. 1989). “20(1) provides that: When a judgment has been fully paid but not satisfied or the satisfaction has been lost, the trial court may authorize the attorney of the judgment creditor to satisfy the same or may by order declare the same satisfied and direct satisfaction to be entered…”
Derrick v. Richard L. Grafe Commodities, Inc. (In Re Derrick), 190 B.R. 346 (Bankr. W.D. Wis. 1995). “However, the debtors have not demonstrated compKance with Wis.Stat. §§ 806.19 and 806.21, the Wisconsin statutes concerning the satisfaction of judgments, and in fact admit that they have not sought the issuance of a satisfaction of judgment in state court.”
Zweber v. Melar Ltd., Inc., 2004 WI App 185 (Wis. Ct. App. 2004). “For the same reason, Wis. Stat. § 806.19 (l)(a) — the satisfaction of judgment statute — implicitly relies on exhaustion or expiration of the appeals period because a defendant has no reason to satisfy a judgment he or she anticipates will be overturned on appeal.”
Matter of Asplund, 21 B.R. 139 (Bankr. W.D. Wis. 1982). “Wis.Stat. § 806.19(4) (1979-80). Upon proper notice, any person who has secured a discharge in bankruptcy may apply to the court where any judgment rendered void by such order of discharge was entered, for an order to satisfy such judgment.”
Epf Corp. v. Pfost, 563 N.W.2d 905 (Wis. Ct. App. 1997). “In 1990, he sought and obtained a circuit court order pursuant to § 806.19(4), Stats., satisfying some, but not all, of the judgments.”
Christakis v. Jeanne D'Arc Credit Union, 29 N.E.3d 823 (Mass. 2015). “may submit an application for an order of satisfaction of the judgment” and “[ujpon satisfaction, a judgment shall cease to be a lien on any real property that the person discharged in bankruptcy owns or later acquires”).”
Studensky v. Buttery Co. (In re Argubright), 532 B.R. 888 (Bankr. W.D. Tex. 2015). “After examining the Wisconsin Legislature’s “policy choices” in enacting similar statutes, the court concluded that the Wisconsin statute- was not preempted by federal law because the statute became effective after the bankruptcy: While Wis.”
Klemme v. Schoneman, 477 N.W.2d 77 (Wis. Ct. App. 1991). “Armed with this discharge, Robert applied to the family court, pursuant to sec. 806.19(4), Stats., for satisfaction of his debt owed to Patricia.”
— Wis. Stat. § 806.19(3) — 1 case
In Re Spore, 105 B.R. 476 (Bankr. W.D. Wis. 1989). “20(1) provides that: When a judgment has been fully paid but not satisfied or the satisfaction has been lost, the trial court may authorize the attorney of the judgment creditor to satisfy the same or may by order declare the same satisfied and direct satisfaction to be entered…”
— Wis. Stat. § 806.19(4) — 13 cases
Megal Dev. Corp. v. Shadof, 2005 WI 151 (Wis. 2005). “1 Defendants Craig and Susan Shadof (Shad-ofs) appeal an order of the circuit court denying their application for satisfaction of a judgment and a judgment lien under Wis. Stat. § 806.19 (4), where the underlying judgment had been discharged in bankruptcy.”
State Cent. Credit Union v. Bigus, 304 N.W.2d 148 (Wis. Ct. App. 1981). “” Further, Bigus’ interpretation is not true to the language of sec. 806.19(4), Stats., and, in effect, rewrites the last sentence to read: The entry of such order of satisfaction of judgment shall bar any other action in the courts of this state against such bankrupt person or…”
Wiebke v. Richardson & Sons, Inc., 265 N.W.2d 571 (Wis. 1978). “1973, currently sec. 806.19(4), Stats. 5 The entry of satisfaction was not the result of a contract into which Wiebke entered voluntarily.”
In Re Spore, 105 B.R. 476 (Bankr. W.D. Wis. 1989). “20(1) provides that: When a judgment has been fully paid but not satisfied or the satisfaction has been lost, the trial court may authorize the attorney of the judgment creditor to satisfy the same or may by order declare the same satisfied and direct satisfaction to be entered…”
Repub. Bank of Chicago v. Lichosyt, 2007 WI App 150 (Wis. Ct. App. 2007). “91(2), [now Wis. Stat. § 806.19 (4)] because of the subsequent bankruptcy action on the part of [the vendee].”
— Wis. Stat. § 806.19(4)(a) — 4 cases
Megal Dev. Corp. v. Shadof, 2005 WI 151 (Wis. 2005). “1 Defendants Craig and Susan Shadof (Shad-ofs) appeal an order of the circuit court denying their application for satisfaction of a judgment and a judgment lien under Wis. Stat. § 806.19 (4), where the underlying judgment had been discharged in bankruptcy.”
Epf Corp. v. Pfost, 563 N.W.2d 905 (Wis. Ct. App. 1997). “In 1990, he sought and obtained a circuit court order pursuant to § 806.19(4), Stats., satisfying some, but not all, of the judgments.”
Scott Smith v. Greg Kleynerman (Wis. Ct. App. 2024).
Ronald D. Fischer v. Amy E. Stimac (Wis. Ct. App. 2023).
— Wis. Stat. § 806.19(4)(b) — 2 cases
Epf Corp. v. Pfost, 563 N.W.2d 905 (Wis. Ct. App. 1997). “In 1990, he sought and obtained a circuit court order pursuant to § 806.19(4), Stats., satisfying some, but not all, of the judgments.”
Scott Smith v. Greg Kleynerman (Wis. Ct. App. 2024).
— Wis. Stat. § 806.19(4)(d) — 2 cases
Megal Dev. Corp. v. Shadof, 2005 WI 151 (Wis. 2005). “1 Defendants Craig and Susan Shadof (Shad-ofs) appeal an order of the circuit court denying their application for satisfaction of a judgment and a judgment lien under Wis. Stat. § 806.19 (4), where the underlying judgment had been discharged in bankruptcy.”
Scott Smith v. Greg Kleynerman (Wis. Ct. App. 2024).
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