Wisconsin Statutes
Wis. Stat. § 846.15 (2026)
Plaintiff’s rights acquired by junior lienor
✓ current as of July 2026
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846.15846.15 Plaintiff’s rights acquired by junior lienor. Any person having a junior lien upon the mortgaged premises or any part thereof or interest therein, may, at any time before such sale, pay to the clerk of court, or the plaintiff or the plaintiff’s assignee, the amount of such judgment, taxes, interest and costs, and costs subsequent to judgment, and shall thereupon be subrogated to all the rights of the plaintiff as to such judgment.
846.15 HistoryHistory: 1973 c. 189 s. 7; Stats. 1973 s. 816.15; Sup. Ct. Order, 67 Wis. 2d 585, 768 (1975); Stats. 1975 s. 846.15; 1993 a. 486.
Notes of Decisions
Cited in 8
cases (1 in the last 5 years), 1995–2021 · leading case: JP Morgan Chase Bank, NA v. Green, 2008 WI App 78 (Wis. Ct. App. 2008).
JP Morgan Chase Bank, NA v. Green, 2008 WI App 78 (Wis. Ct. App. 2008). “JP Morgan did not expressly refer to Wis. Stat. § 846.15 in the circuit court.”
Repub. Bank of Chicago v. Lichosyt, 2007 WI App 150 (Wis. Ct. App. 2007). “Because there is no procedure for a sale in a strict foreclosure action, it is not suited, as it presently exists, for resolving the competing interests among judgment lienholders or among the three-way configuration of vendor, vendee, and even one judgment lienholder.”
Carolina Builders Corp. v. Dietzman, 2007 WI App 201 (Wis. Ct. App. 2007). “01 (1), which provides that "in actions for the foreclosure of mortgages upon real estate, if the plaintiff recover[s], the court shall render judgment of foreclosure and sale, as provided in this chapter, of the mortgaged premises . . . Wis.”
Veritas Steel, LLC v. Lunda Constr. Co., 2020 WI 3 (Wis. 2020). “Lunda also asserted that the strict foreclosure procedures employed were grounded in common law or statutory fraud and therefore, permit Lunda to collect its debt from Veritas's assets.”
Matter of Plunkett, 191 B.R. 768 (Bankr. E.D. Wis. 1995). “Wis.Stat. § 846.15(2) states that “there shall be no presumption that such premises sold for their fair value and no sale shall be confirmed and judgment for deficiency rendered, until the court is satisfied that the fair value of the premises sold has been credited on the…”
In Re Midwest Props. of Shawano, LLC, 442 B.R. 278 (Bankr. D. Del. 2010). “In response, FCCU argues that Midwest Properties’ only recourse under state law at this stage of the proceedings is to “redeem” the property by paying the full amount of the foreclosure judgment, plus *285 taxes, interest and costs, to the clerk of court or the plaintiff.”
Heartland Credit Union v. Chocolaterian LLC (Wis. Ct. App. 2021). “§ 846.15, a junior lienholder has the option to acquire the plaintiff’s rights.”
Gene Frederickson Trucking & Excavating, Inc. v. Wagner, 928 N.W.2d 805 (Wis. Ct. App. 2019). “§ 846.15 (2017-18). For these reasons, the extinguishment of a junior lien, even if done intentionally, is neither uncommon nor improper.”
— Wis. Stat. § 846.15(2) — 1 case
Matter of Plunkett, 191 B.R. 768 (Bankr. E.D. Wis. 1995). “Wis.Stat. § 846.15(2) states that “there shall be no presumption that such premises sold for their fair value and no sale shall be confirmed and judgment for deficiency rendered, until the court is satisfied that the fair value of the premises sold has been credited on the…”
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