Wis. Stat. » CHAPTER 893 — LIMITATIONS OF COMMENCEMENT OF ACTIONS AND PROCEEDINGS; PROCEDURE FOR CLAIMS AGAINST GOVERNMENTAL UNITS
Wisconsin Statutes

Wis. Stat. § 893.15 (2026)

Effect of an action in a non-Wisconsin forum on a Wisconsin cause of action

✓ current as of July 2026
Find cases: SyfertCases citing this section WI-LEGdocs.legis.wisconsin.gov JustiaChapter on Justia CornellLII Search CasesGoogle Scholar
893.15893.15 Effect of an action in a non-Wisconsin forum on a Wisconsin cause of action.
Down
Up
893.15(1)(1) In this section “a non-Wisconsin forum” means all courts, state and federal, in states other than this state and federal courts in this state.
893.15(2)(2) In a non-Wisconsin forum, the time of commencement or final disposition of an action is determined by the local law of the forum.
893.15(3)(3) A Wisconsin law limiting the time for commencement of an action on a Wisconsin cause of action is tolled from the period of commencement of the action in a non-Wisconsin forum until the time of its final disposition in that forum.
893.15(4)(4) Subsection (3) does not apply to an action commenced on a Wisconsin cause of action in a non-Wisconsin forum after the time when the action is barred by a law of the forum limiting the time for commencement of an action.
893.15(5)(5) If an action is commenced in a non-Wisconsin forum on a Wisconsin cause of action after the time when the Wisconsin period of limitation has expired but before the foreign period of limitation has expired, the action in the non-Wisconsin forum has no effect on the Wisconsin period of limitation.
893.15 HistoryHistory: 1979 c. 323.
893.15 NoteJudicial Council Committee’s Note, 1979: Sub. (1) defines the term “a non-Wisconsin forum”. “State” is defined in s. 990.01 (40) to include the District of Columbia, Puerto Rico, and territories of the United States.
893.15 AnnotationSub. (2) determines the commencement and termination of an action in a non-Wisconsin forum by the law of that forum. “Local law” is referred to so that the non-Wisconsin court determining the commencement of an action in, for example, Illinois will use Illinois law, not including any other law which an Illinois court might use under a choice of law theory.
893.15 AnnotationSub. (3) applies the tolling effect of Wisconsin statutes to actions on Wisconsin causes of action brought in federal courts in Wisconsin and to all other courts, state and federal, in the United States.
893.15 AnnotationSub. (4) prevents the commencement of an action in a forum whose statute of limitations has run from extending the Wisconsin tolling period.
893.15 AnnotationSub. (5) prevents the maintenance of an action in a non-Wisconsin forum from extending a Wisconsin statute of limitations. [Bill 326-A]
893.15 AnnotationA voluntarily dismissed federal action does not toll the Wisconsin statute of limitations. A voluntarily dismissed federal action is a nullity, having no effect on a statute of limitations. Culbert v. Ciresi, 2003 WI App 158, 266 Wis. 2d 189, 667 N.W.2d 825, 02-3320.
Notes of Decisions
Cited in 26 cases (4 in the last 5 years), 1966–2025 · leading case: Turner v. Taylor, 2003 WI App 256 (Wis. Ct. App. 2003).
Sort: Relevance Newest Treatment
Turner v. Taylor, 2003 WI App 256 (Wis. Ct. App. 2003). · cites it 18× “33 (8) and Wis. Stat. § 893.15 (5) (1977), allowed for the enforcement of easements for up to sixty years.”
State v. Barkdoll, 298 N.W.2d 539 (Wis. 1980). · cites it 26× “This court granted defendants’ petition for review to consider the applicability of sec. 893.15, Stats., to the instant case.”
State Historical Soc'y of Wisconsin v. Vill. of Maple Bluff, 332 N.W.2d 792 (Wis. 1983). · cites it 12× “This case involves the interpretation of sec. 893.15, Stats. (1977) 1 (now sec. 893.”
Artis v. Dist. of Columbia, 583 U.S. 71 (2018). “See also Wis. Stat. §893.15 (3) (2011–2012) (“A Wisconsin law limiting the time for commencement of an action on a Wisconsin cause of action is tolled from the period of commencement of the action in a non-Wisconsin forum until the time of its final disposition in that forum.”
Johnson v. Cnty. of Crawford, 536 N.W.2d 167 (Wis. Ct. App. 1995). · cites it 4× “[4] Section 893.15(2), STATS., provides that, for purposes of tolling a statute of limitations on the basis of an action brought in a non-Wisconsin forum, which is defined to include federal courts, the law of the forum determines the time of commencement or final disposition of…”
Delonga v. Diocese of Sioux Falls, 329 F. Supp. 2d 1092 (D.S.D. 2004). · cites it 2× “Wis. Stat. § 893.15 (2) states: “ In a non-Wisconsin forum, the time of commencement or final disposition of an action is determined by the local law of the forum.”
Culbert v. Ciresi, 2003 WI App 158 (Wis. Ct. App. 2003). · cites it 3× “It is integral to determining when the federal action was commenced, which is what Wis. Stat. § 893.15 (2) directs us to examine.”
Figliuzzi v. Carcajou Shooting Club of Lake Koshkonong, 516 N.W.2d 410 (Wis. 1994). · cites it 2× “Section 893.15(5) prescribed a sixty year period of limitation for easements.”
Tilstra v. Bou-Matic, LLC, 1 F. Supp. 3d 900 (W.D. Wis. 2014). · cites it 4× “" However, as Bou-Matic points out, it is subsection (3) of § 893.15 that specifically addresses the effect of an action filed in a non-Wisconsin forum: A Wisconsin law limiting the time for commencement of an action on a Wisconsin cause of action is tolled from the period of…”
Schertz v. Waupaca Cnty., 683 F. Supp. 1551 (E.D. Wis. 1988). · cites it 2× “…Judgment at 14. 26 . The relevant statutes of limitation have been tolled during the pendency of this action. See Wis.Stat. § 893.15.”
Cont'l Assurance Co. v. Am. Bankshares Corp., 601 F. Supp. 277 (E.D. Wis. 1985). · cites it 2× “The plaintiff now admits that, pursuant to Wis.Stat. § 893.15, its state law claim may not be barred by the state statute of limitations.”
Herzog v. Bujniewicz, 145 N.W.2d 124 (Wis. 1966). · cites it 2× “We agree with the trial court that if this section bars evidence of acts of adverse possession occurring prior to thirty years before commencement of the action that the evidence relating to acts within the thirty-year period is not sufficient to establish title in plaintiff by…”
Show all 26 citing cases →
— Wis. Stat. § 893.15(1) — 2 cases
State v. Barkdoll, 298 N.W.2d 539 (Wis. 1980). “This court granted defendants’ petition for review to consider the applicability of sec. 893.15, Stats., to the instant case.”
Tilstra v. Bou-Matic, LLC, 1 F. Supp. 3d 900 (W.D. Wis. 2014). “" However, as Bou-Matic points out, it is subsection (3) of § 893.15 that specifically addresses the effect of an action filed in a non-Wisconsin forum: A Wisconsin law limiting the time for commencement of an action on a Wisconsin cause of action is tolled from the period of…”
— Wis. Stat. § 893.15(2) — 2 cases
Johnson v. Cnty. of Crawford, 536 N.W.2d 167 (Wis. Ct. App. 1995). “[4] Section 893.15(2), STATS., provides that, for purposes of tolling a statute of limitations on the basis of an action brought in a non-Wisconsin forum, which is defined to include federal courts, the law of the forum determines the time of commencement or final disposition of…”
Colborn v. Netflix Inc (E.D. Wis. 2020).
— Wis. Stat. § 893.15(3) — 1 case
Colborn v. Netflix Inc (E.D. Wis. 2020).
— Wis. Stat. § 893.15(4) — 1 case
State Historical Soc'y of Wisconsin v. Vill. of Maple Bluff, 332 N.W.2d 792 (Wis. 1983). “This case involves the interpretation of sec. 893.15, Stats. (1977) 1 (now sec. 893.”
— Wis. Stat. § 893.15(5) — 3 cases
Turner v. Taylor, 2003 WI App 256 (Wis. Ct. App. 2003). “33 (8) and Wis. Stat. § 893.15 (5) (1977), allowed for the enforcement of easements for up to sixty years.”
Figliuzzi v. Carcajou Shooting Club of Lake Koshkonong, 516 N.W.2d 410 (Wis. 1994). “Section 893.15(5) prescribed a sixty year period of limitation for easements.”
Figliuzzi v. Carcajou Shooting Club, 502 N.W.2d 876 (Wis. Ct. App. 1993).
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.