Wisconsin Statutes
Wis. Stat. § 806.245 (2026)
Indian tribal documents: full faith and credit
✓ current as of July 2026
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806.245(1)(1) The judicial records, orders and judgments of an Indian tribal court in Wisconsin and acts of an Indian tribal legislative body shall have the same full faith and credit in the courts of this state as do the acts, records, orders and judgments of any other governmental entity, if all of the following conditions are met:
806.245(1)(a)(a) The tribe which creates the tribal court and tribal legislative body is organized under 25 USC 461 to 479.
806.245(1)(e)(e) The tribal court certifies that it grants full faith and credit to the judicial records, orders and judgments of the courts of this state and to the acts of other governmental entities in this state.
806.245(1m)(1m) The public acts, records, and judicial proceedings of any Indian tribe that are applicable to an Indian child custody proceeding, as defined in s. 48.028 (2) (d), or an Indian juvenile child custody proceeding, as defined in s. 938.028 (2) (b), shall be given full faith and credit by the state as provided in s. 48.028 (3) (f) or 938.028 (3) (f).
806.245(2)(a)(a) Copies of acts of a tribal legislative body shall be authenticated by the certificate of the tribal chairperson and tribal secretary.
806.245(2)(b)(b) Copies of records, orders and judgments of a tribal court shall be authenticated by the attestation of the clerk of the court. The seal, if any, of the court shall be affixed to the attestation.
806.245(3)(3) In determining whether a tribal court is a court of record, the circuit court shall determine that:
806.245(3)(b)(b) Either a transcript or an electronic recording of the proceeding at issue in the tribal court is available.
806.245(4)(4) In determining whether a tribal court judgment is a valid judgment, the circuit court on its own motion, or on the motion of a party, may examine the tribal court record to assure that:
806.245(4)(a)(a) The tribal court had jurisdiction of the subject matter and over the person named in the judgment.
806.245(4)(e)(e) The judgment was procured in compliance with procedures required by the rendering court.
806.245(4)(f)(f) The proceedings of the tribal court comply with the Indian civil rights act of 1968 under 25 USC 1301 to 1341.
806.245(5)(5) No lien or attachment based on a tribal court judgment may be filed, entered in the judgment and lien docket or recorded in this state against the real or personal property of any person unless the judgment has been given full faith and credit by a circuit court under this section.
806.245(6)(6) A foreign protection order, as defined in s. 813.128 (1g) (c), issued by an Indian tribal court in this state shall be accorded full faith and credit under s. 813.128.
806.245 AnnotationThe prior action rule, which provides that, when one court assumes jurisdiction, it is reversible error for another court to do so, does not apply to the court of an independent sovereign. In this case, principles of comity required state and tribal courts to confer and allocate jurisdiction among themselves. Teague v. Bad River Band of Lake Superior Tribe of Chippewa Indians, 2000 WI 79, 236 Wis. 2d 384, 612 N.W.2d 709, 98-3150. See also Teague v. Bad River Band of Lake Superior Tribe of Chippewa Indians, 2003 WI 118, 265 Wis. 2d 64, 665 N.W.2d 899, 01-1256.
806.245 AnnotationFull faith and credit does not require automatically admitting to the state bar any attorney who was admitted to a tribal court in Wisconsin. Helgemo v. Board of Bar Examiners, 2002 WI 57, 253 Wis. 2d 82, 644 N.W.2d 912, 01-2611.
Notes of Decisions
Cited in 9
cases, 1997–2012 · leading case: Teague v. Bad River Chippewa Indians, 2003 WI 118 (Wis. 2003).
Teague v. Bad River Chippewa Indians, 2003 WI 118 (Wis. 2003). “This case is before the court on certification from the Court of Appeals, District III, pursuant to Wis.”
Teague v. Bad River Band of the Lake Superior Tribe of Chippewa Indians, 2000 WI 79 (Wis. 2000). “Specifically, the case raises the question of whether under Wis. Stat. § 806.245 (1995-96), 1 a tribal court judgment can be denied full faith and credit because a complaint concerning the same subject matter was filed first in state circuit court.”
Teague v. Bad River Band of Lake Superior Tribe, 2003 WI 118 (Wis. 2003). “1 The parties dispute whether a default judgment on the merits from the Bad River Band Tribal Court should be granted full faith and credit under Wis. Stat. § 806.245 when the same matter has also resulted in a judgment and orders from a Wisconsin circuit court.”
Mary Jane WILSON, Plaintiff-Appellee, v. Thomas David MARCHINGTON; Inland Empire Shows, Inc., Defendants-Appellants, 127 F.3d 805 (9th Cir. 1997). “12, § 728 (permitting the Supreme Court of the State of Oklahoma to extend full faith and credit to tribal court judgments); Wis. Stat. § 806.245 (granting full faith and credit to judgments of Wisconsin Indian tribal courts); Wyo.”
Teague v. Bad River Band of the Lake Superior Tribe of Chippewa Indians, 599 N.W.2d 911 (Wis. Ct. App. 1999). “The Band contends the circuit court erred by: (1) refusing to give full faith and credit to a tribal court judgment declaring the employment contracts null and void pursuant to § 806.245, Stats.; (2) finding that the Band was estopped from arguing as an affirmative defense that…”
Kroner v. Oneida Seven Generations Corp., 2012 WI 88 (Wis. 2012). “How does the proposed rule impact the application of Wis. Stat. § 806.245 (full faith and credit)? But there were many more.”
MacArthur v. San Juan Cnty., 391 F. Supp. 2d 895 (D. Utah 2005). “12, § 728 (permitting the Supreme Court of the State of Oklahoma to extend full faith and credit to tribal court judgments); Wis. Stat. § 806.245 (granting full faith and credit to judgments of Wisconsin Indian tribal courts); Wyo.”
In the Matter of Bar Admission of Helgemo, 2002 WI 57 (Wis. 2002). “[6] *94 [6] ¶ 18. We turn to Ms. Helgemo's claim that the Board's denial of her bar application fails "to give full faith and credit to the admission of petitioner to practice before the Supreme Court of the Ho-Chunk Nation pursuant to Wis.”
In re the Outstanding Obligations of Williams, 6 Am. Tribal Law 234 (2005). “, Wis. Stat. § 806.245 (4) (2004). . Although not binding in this jurisdiction, the Court regards the relevant statutory provisions as persuasive authority.”
— Wis. Stat. § 806.245(1) — 3 cases
Teague v. Bad River Chippewa Indians, 2003 WI 118 (Wis. 2003). “This case is before the court on certification from the Court of Appeals, District III, pursuant to Wis.”
Teague v. Bad River Band of Lake Superior Tribe, 2003 WI 118 (Wis. 2003). “1 The parties dispute whether a default judgment on the merits from the Bad River Band Tribal Court should be granted full faith and credit under Wis. Stat. § 806.245 when the same matter has also resulted in a judgment and orders from a Wisconsin circuit court.”
In the Matter of Bar Admission of Helgemo, 2002 WI 57 (Wis. 2002). “[6] *94 [6] ¶ 18. We turn to Ms. Helgemo's claim that the Board's denial of her bar application fails "to give full faith and credit to the admission of petitioner to practice before the Supreme Court of the Ho-Chunk Nation pursuant to Wis.”
— Wis. Stat. § 806.245(1)(e) — 1 case
Teague v. Bad River Chippewa Indians, 2003 WI 118 (Wis. 2003). “This case is before the court on certification from the Court of Appeals, District III, pursuant to Wis.”
— Wis. Stat. § 806.245(4) — 1 case
Teague v. Bad River Band of the Lake Superior Tribe of Chippewa Indians, 599 N.W.2d 911 (Wis. Ct. App. 1999). “The Band contends the circuit court erred by: (1) refusing to give full faith and credit to a tribal court judgment declaring the employment contracts null and void pursuant to § 806.245, Stats.; (2) finding that the Band was estopped from arguing as an affirmative defense that…”
— Wis. Stat. § 806.245(4)(a) — 2 cases
Teague v. Bad River Chippewa Indians, 2003 WI 118 (Wis. 2003). “This case is before the court on certification from the Court of Appeals, District III, pursuant to Wis.”
Teague v. Bad River Band of Lake Superior Tribe, 2003 WI 118 (Wis. 2003). “1 The parties dispute whether a default judgment on the merits from the Bad River Band Tribal Court should be granted full faith and credit under Wis. Stat. § 806.245 when the same matter has also resulted in a judgment and orders from a Wisconsin circuit court.”
— Wis. Stat. § 806.245(4)(c) — 3 cases
Teague v. Bad River Band of the Lake Superior Tribe of Chippewa Indians, 599 N.W.2d 911 (Wis. Ct. App. 1999). “The Band contends the circuit court erred by: (1) refusing to give full faith and credit to a tribal court judgment declaring the employment contracts null and void pursuant to § 806.245, Stats.; (2) finding that the Band was estopped from arguing as an affirmative defense that…”
Teague v. Bad River Chippewa Indians, 2003 WI 118 (Wis. 2003). “This case is before the court on certification from the Court of Appeals, District III, pursuant to Wis.”
Teague v. Bad River Band of Lake Superior Tribe, 2003 WI 118 (Wis. 2003). “1 The parties dispute whether a default judgment on the merits from the Bad River Band Tribal Court should be granted full faith and credit under Wis. Stat. § 806.245 when the same matter has also resulted in a judgment and orders from a Wisconsin circuit court.”
— Wis. Stat. § 806.245(4)(d) — 1 case
Teague v. Bad River Band of the Lake Superior Tribe of Chippewa Indians, 599 N.W.2d 911 (Wis. Ct. App. 1999). “The Band contends the circuit court erred by: (1) refusing to give full faith and credit to a tribal court judgment declaring the employment contracts null and void pursuant to § 806.245, Stats.; (2) finding that the Band was estopped from arguing as an affirmative defense that…”
— Wis. Stat. § 806.245(l)(e) — 1 case
Teague v. Bad River Band of Lake Superior Tribe, 2003 WI 118 (Wis. 2003). “1 The parties dispute whether a default judgment on the merits from the Bad River Band Tribal Court should be granted full faith and credit under Wis. Stat. § 806.245 when the same matter has also resulted in a judgment and orders from a Wisconsin circuit court.”
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