Wis. Stat. » CHAPTER 816 — REMEDIES SUPPLEMENTARY TO EXECUTION
Wisconsin Statutes

Wis. Stat. § 816.04 (2026)

Appointment of receiver

✓ current as of July 2026
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816.04816.04 Appointment of receiver. A receiver may be appointed but before appointing a receiver the court or judge shall ascertain, if practicable, whether any other supplementary proceedings are pending against the judgment debtor, and if there be any, the plaintiff therein shall have notice to appear and shall have notice of all subsequent proceedings in relation to such receivership. There shall be but one receivership at any time.
816.04 HistoryHistory: Sup. Ct. Order, 67 Wis. 2d 585, 761 (1975); Stats. 1975 s. 816.04.
816.04 AnnotationViolation of the “one receivership” rule does not create a statutory right of action in a judgment debtor. Candee v. Egan, 84 Wis. 2d 348, 267 N.W.2d 890 (1978).
816.04 AnnotationA receiver’s lien is governed by common law, as this section is silent on the subject. The lien is superior against other creditors claims on simple contracts from the time the creditor serves the debtor with notice to appear at supplementary proceedings under this chapter. No additional steps to perfect the lien are required. Mann v. Bankruptcy Estate of Badger Lines, Inc., 224 Wis. 2d 646, 590 N.W.2d 270 (1999), 98-0888. But see Associated Bank N.A. v. Collier, 2014 WI 62, 355 Wis. 2d 343, 852 N.W.2d 443, 11-2597.
Notes of Decisions
Cited in 12 cases (3 in the last 5 years), 1979–2025 · leading case: Associated Bank N.A. v. Jack W. Collier, 2014 WI 62 (Wis. 2014).
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Associated Bank N.A. v. Jack W. Collier, 2014 WI 62 (Wis. 2014). · cites it 10× “Wis. Stat. § 816.04 ; Wis. Stat. § 816.08 .”
Tralmer Sales & Serv., Inc. v. Erickson, 521 N.W.2d 182 (Wis. Ct. App. 1994). · cites it 6× “Tralmer asserts that under § 816.04, Stats., at the request of a judgment creditor a trial court must appoint a supplementary receiver, provided that no other supplementary receiver has been appointed.”
Crown Castle USA, Inc. v. Orion Constr. Grp., LLC, 2012 WI 29 (Wis. 2012). · cites it 2× “*280 A receiver could be appointed under Wis. Stat. § 816.04 , see generally Mann v.”
Appeal of Mann v. Bankr. Est. of Badger Lines, Inc., 590 N.W.2d 270 (Wis. 1999). · cites it 4× “Wis. Stat. § 816.04 . The court commissioner's orders were served on Badger and filed with the Milwaukee County clerk of court.”
In re Badger Lines, Inc., 140 F.3d 691 (7th Cir. 1998). · cites it 2× “We are asked to determine whether a creditor who obtains a judgment lien against a debtor and who institutes supplementary proceedings under Wis. Stat. § 816.04 is required by Wisconsin law to perfect that lien, and if so, how and when that lien is perfected.”
In Re Badger Lines, Inc., 206 B.R. 521 (E.D. Wis. 1997). · cites it 4× “§ 816.04 for creditor Emerald Industrial Leasing Corporation [“Emerald”] filed a motion seeking a turnover of funds of Badger’s estate on the ground that he was the holder of a judicial lien under 11 U.”
Glover v. Marine Bank of Beaver Dam, 345 N.W.2d 449 (Wis. 1984). “) Although the Wisconsin statutes no longer contain a provision stating that the judgment of foreclosure shall contain an “order” directing that judgment for deficiencies shall be rendered, sec. 816.04, Stats. (1973), presently numbered sec.”
Dawson v. Goldammer, 2006 WI App 158 (Wis. Ct. App. 2006). “§ 816.04 grants the trial court the authority to appoint a receiver to help a judgment creditor achieve satisfaction.”
Dep't of Revenue v. Milwaukee MacK Sales, Inc., 280 N.W.2d 274 (Wis. 1979). · cites it 2× “Accordingly, on March 24, 1976 on motion of the Department, Barnett Franks was appointed receiver by the court commissioner of Wal-worth County pursuant to sec. 816.04, Stats. 3 On June 21, 1976 Mack Sales gave notice of a public sale of two trucks which B.”
Greenpoint Asset Mgmt. II LLC v. Hallick (Bankr. E.D. Wis. 2022). · cites it 2× “Finding too little guidance in Wisconsin precedent the Seventh Circuit certified the following question to the Wisconsin Supreme Court: “Does Wisconsin law require that a lien obtained by a judgment creditor who institutes supplementary proceedings under Wis. Stat. § 816.04 be…”
Leonard Pozner v. James Fetzer (Wis. Ct. App. 2023). “§ 816.04 specifically grants circuit courts discretionary authority to appoint a receiver to help a creditor satisfy a judgment.”
Anthony Frank Kapalczynski v. Bonnie Mae Krause-Kapalczynski (Wis. Ct. App. 2025). “§ 816.04 specifically grants circuit courts discretionary authority to appoint a receiver to help a creditor satisfy a judgment.”
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.