{"meta":{"key":"s_wi--pass-19","task":"S_WI","title":"Bounded citation-status correction to","parent_title":"Wisconsin debt and debt relief law","edition":"pass-19","path":"/research/s_wi--pass-19/","kind":"split_pass","category":"state","role":"state","area_numbers":[66],"groups":["collections"],"date":"2026-10-27","tables":12,"claims":23,"sources":5,"review_status":"P17pre2009citation_and_dependent_support_repairs_addressed_with_holds","review_complete":true,"sha256":"3b060ced1dedae8122cd1b2db5727211dbc7ebdcd994bd89d1ae7f4d92864be3","headings":["Bounded citation-status correction to PASS-17","1. Citation rule and currentness boundary","Operative distinction established by the sources read","Current integrated-body hold","2. Exact replacements for the two principal PASS-17 claim cells","S_WI-P17-C050 — full old-to-new replacement","S_WI-P17-C027 — full old-to-new replacement","3. Replacement source-status and case-grid cells","4. Remaining affected PASS-17 atomic-claim cells","Preserved supporting anchors—not fresh PASS-19 reads","5. Exact narrative and self-check replacements","PASS-17 §8: good cause and excusable neglect","PASS-17 §12: genuine voidness","PASS-17 §26: case-grid status sentence","PASS-17 final self-check","6. New citation-rule source register","7. New atomic correction claims","8. Complete affected PASS-17 coverage replacements","9. Old-to-new crosswalk","10. Two fictional citation-routing examples","Example A — Historical 1998 unpublished opinion","Example B — Authored 2019 unpublished opinion","11. Complete correction-scope coverage","12. Retained holds and territorial limits","Deferred holds","Territorial and local scope","13. Final provenance and count reconciliation","Researcher self-check"],"generation_provenance":{"actual_route":"regular_chat_adaptive_models","actual_model":"GPT-6","actual_mode":"Pro","provenance_limit":"Actual documented capture labels only; missing labels remain unknown. No preferred setting is inferred as actual execution."},"public_id":"S_WI/pass-19","facets":{"geography":["us","us-wi"],"debt_type":[],"stage":[],"subject":[]},"scope":"OnlyreviewedP17pre2009unpublishedcitationstatusanddependentatomiccoverage/sourcecells; P18unreviewednotpremise.","pending_corrections":0},"markdown":"# SettleADebt S_WI PASS-19\n\n## Bounded citation-status correction to PASS-17\n\n**Fresh access date:** October 26, 2026, America/Los_Angeles; October 27, 2026 UTC. Individual source-opening clock times are not asserted.\n\n**Scope:** This corrects PASS-17’s treatment of unpublished Wisconsin opinions and the claims dependent on those sources. It does not rerun reopening law, revisit the 18 original workflows, adopt PASS-16 or PASS-18, or resolve an actual service or judgment issue.\n\n**Disposition:** The blanket statement that all PASS-17 sources S022–S027 are available as persuasive authority is withdrawn. *Benitez* (1998), *Zander* (2004), and *Gregory* (1999) remain historical research reads, but are **not generally citable for persuasive value in Wisconsin courts**. *Ryan* (2019) and *Ripco* (2016) have been narrowly rechecked for authorship, date, nonpublication, and the passages necessary to repair the affected claims. *Ceron* retains its separately attributed PASS-17 researcher-access history; this pass did not reopen or newly verify it.\n\n## 1. Citation rule and currentness boundary\n\n### Operative distinction established by the sources read\n\nThe Wisconsin Supreme Court’s **2009 WI 2**, entered January 6, 2009 and effective July 1, 2009, amended Rule 809.23(3) as follows:\n\n| Provision | Rule established by the order |\n| --- | --- |\n| **(3)(a)** | Unpublished opinions ordinarily cannot be cited in Wisconsin courts as precedent or authority. The specified exceptions are claim preclusion, issue preclusion, and law of the case, together with the separate permission in paragraph (b). |\n| **(3)(b): date and authorship** | Persuasive citation is permitted for an unpublished opinion issued **on or after July 1, 2009**, authored by a member of a three-judge panel or by a single judge under §752.31(2). |\n| **(3)(b): excluded formats** | Per curiam opinions, memorandum opinions, summary-disposition orders, and other orders do not qualify as authored opinions for this permission. |\n| **(3)(b): legal weight** | A qualifying opinion is not binding precedent. A court need not distinguish or discuss it; a party need not research or cite it. |\n| **(3)(c)** | A party actually citing an unpublished opinion must file and serve a copy with the brief or other paper containing the citation. |\n\n**New claims S_WI-P19-C001–C005.** Primary authority:\nhttps://www.wicourts.gov/sc/scord/DisplayDocument.html?content=html&seqNo=35116, §§1–3, amending Rule 809.23(3)(a)–(c). [Wisconsin Court System](https://www.wicourts.gov/sc/scord/DisplayDocument.html?content=html&seqNo=35116)\n\nThe official Court of Appeals opinions guide, as served on the access date, confirms the pre-/post-July 1, 2009 distinction. Its citation guidance calls for the case caption, case number, unpublished designation, paragraph, court, and decision date; it cautions against using an unpublished opinion’s public-domain table citation as though it identified the individual opinion. This is court guidance, not another amendment. **S_WI-P19-C006.**\n\nhttps://www.wicourts.gov/opinions/appeals2.htm, headings **“Precedential value of opinions”** and **“Citation of unpublished opinions.”** [Wisconsin Court System](https://www.wicourts.gov/opinions/appeals2.htm)\n\n### Current integrated-body hold\n\nThe supplied current Legislature endpoint was attempted once in this pass and timed out:\n\nhttps://docs.legis.wisconsin.gov/statutes/statutes/809/iii/23/3\n\nThe official rule order supplies the complete relevant amendment text, and the presently accessible court guide corroborates the central citation distinction. Nevertheless, **the 2009 order is not represented as a complete amendment-chain audit through October 2026**, and the guide’s availability today is not a legal commencement date. **S_WI-P19-C006.** (Invalid URL)\n\nThe rule restricts use **in court as authority**. It does not require deletion of an older opinion from a historical research record, nor does it establish that the opinion’s historical reasoning was false.\n\n## 2. Exact replacements for the two principal PASS-17 claim cells\n\n### S_WI-P17-C050 — full old-to-new replacement\n\n**Old assertion:** “Unpublished cases are persuasive, not precedential.”\n**Old actor:** Appellate researcher.\n**Old sources:** S_WI-P17-S022–S027.\n**Old qualification:** “Published authority controls.”\n\n**Correct replacement:**\n\n**S_WI-P17-C050 — Citation status of unpublished Wisconsin opinions.**\nA researcher or litigant must classify an unpublished opinion by issuance date, authorship, format, and proposed use. An unpublished opinion issued before July 1, 2009 is not generally citable as persuasive authority in Wisconsin courts. The limited claim-preclusion, issue-preclusion, and law-of-the-case exceptions must be established separately. An eligible authored opinion issued on or after July 1, 2009 may be cited for persuasive value, but is not binding; excluded opinion/order formats do not qualify. If cited, a copy must be filed and served with the citing paper. Consequently, S_WI-P17-S024, S026, and S027 are historical reads—not ordinary persuasive authorities. S023 and S025 satisfy the authorship/date/nonpublication conditions observed in the limited fresh check. S022 remains subject to its separate access and authorship-verification limits.\n\n**Authority:** S_WI-P19-S001, Rule 809.23(3)(a)–(c); S_WI-P19-S002.\n**Currentness limit:** Complete current integrated rule and full subsequent-history review remain held.\n**Registry status:** A066/A097/A098 open; no acceptance. [Wisconsin Court System+1](https://www.wicourts.gov/sc/scord/DisplayDocument.html?content=html&seqNo=35116)\n\n### S_WI-P17-C027 — full old-to-new replacement\n\n**Old assertion:** “Unpublished Benitez supports distinct §806.07(d) theory.”\n**Old actor:** Void-service challenger.\n**Old source:** S_WI-P17-S024.\n**Old qualification:** “Persuasive only.”\n\n**Correct replacement:**\n\n**S_WI-P17-C027 — Historical Benitez discussion, not ordinary persuasive authority.**\nPASS-17 recorded that the unpublished 1998 *Benitez* opinion distinguished an attack on a supposedly void judgment from reopening a valid default. That historical description is retained as an attributed research read only. Because the opinion predates July 1, 2009, it is not ordinarily citable for persuasive value under Rule 809.23(3). No claim-preclusion, issue-preclusion, or law-of-the-case predicate is supplied here. Its then-applicable six-month statutory discussion is historical and is not a current deadline. The opinion is therefore removed as ordinary persuasive support for a present small-claims voidness exception. That exception remains unresolved in the reviewed work; *Ripco* assumed it without deciding it.\n\n**Sources:** Historical S_WI-P17-S024; citation rule S_WI-P19-S001; limited fresh *Ripco* check under existing S_WI-P17-S023.\n**Effect:** Withdraw the legal-support status, not the historical source record or its historical outcome.\n**Registry status:** A066/A097/A098 open; no actual judgment is declared void. [Wisconsin Court System+1](https://www.wicourts.gov/sc/scord/DisplayDocument.html?content=html&seqNo=35116)\n\n## 3. Replacement source-status and case-grid cells\n\nThe following six rows replace the affected status/read-limit cells in the PASS-17 source register and corresponding case grid. They are **not six new PASS-19 sources**.\n\n| Existing source ID | Official document and exact URL | Corrected citation status and substantive limit | Access attribution |\n| --- | --- | --- | --- |\n| **S_WI-P17-S024** | Wisconsin Court of Appeals, *Benitez v. Fasick*, No. 97-3572, May 27, 1998. https://www.wicourts.gov/ca/opinion/DisplayDocument.html?content=html&seqNo=13362 — unnumbered discussion of §§799.29 and 806.07(d); HTML, PDF indexes not applicable | **Historical research only; not generally citable for persuasion.** Limited Rule 809.23(3)(a) exceptions are not established. The historical six-month provision is obsolete for current-deadline purposes. Does not resolve the modern small-claims void-service exception. | PASS-17 reported body read on October 26 Pacific/October 27 UTC. **Not reopened in PASS-19.** Historical detail and six-month qualification are separately attributed to the supplied record/review. |\n| **S_WI-P17-S026** | Wisconsin Court of Appeals, *Zander Solutions v. Koenigs*, No. 04-0764, October 28, 2004. https://www.wicourts.gov/ca/opinion/DisplayDocument.html?content=html&seqNo=7390 — ¶¶5–8; HTML | **Historical research only; not generally citable for persuasion.** Its mailed-answer/neglect discussion is removed as ordinary persuasive support for C007, C011, C012, and C020. No finding that its historical doctrine was false. | PASS-17 reported body read on October 26 Pacific/October 27 UTC. **Not reopened in PASS-19.** |\n| **S_WI-P17-S027** | Wisconsin Court of Appeals, *Gregory v. United Parcel Service*, No. 98-3024, September 29, 1999. https://www.wicourts.gov/ca/opinion/DisplayDocument.html?content=html&seqNo=14670 — unnumbered notice discussion; HTML | **Historical research only; not generally citable for persuasion.** Retain the summary-judgment-motion notice posture; do not convert it into a general default-judgment or medical-emergency rule. | PASS-17 reported body read on October 26 Pacific/October 27 UTC. **Not reopened in PASS-19.** |\n| **S_WI-P17-S025** | Wisconsin Court of Appeals, *Ryan v. Friday*, No. 2018AP1354, May 14, 2019. https://wicourts.gov/ca/opinion/DisplayDocument.pdf?content=pdf&seqNo=240493 — ¶1 and footnote 1; ¶¶9–12, 16–19; first page unnumbered/zero **0**; printed pp.4–6/zero **3–5** | **Eligible authored post-2009 unpublished opinion; persuasive, not binding.** The opinion identifies Dugan, J., acting under §752.31(2)(a), and states it will not be published. Retain only the actual discretion, excusable-neglect, and appellate-posture propositions. | **Limited fresh PASS-19 check.** Text and images at zero indexes **0, 3, 4, 5** inspected. No subsequent-history or complete-citator certification. |\n| **S_WI-P17-S023** | Wisconsin Court of Appeals, *Ripco Credit Union v. Kennedy*, No. 2015AP1280, February 23, 2016. https://www.wicourts.gov/ca/opinion/DisplayDocument.pdf?content=pdf&seqNo=162063 — ¶1/footnote 1; ¶¶2, 9–11, 15; first page unnumbered/zero **0**; printed p.5/zero **4**; printed p.9/zero **8** | **Eligible authored post-2009 unpublished opinion; persuasive, not binding.** Hruz, J., decided it under §752.31(2). It **assumed without deciding** the late void-judgment exception and resolved that appeal on its service facts. It did not establish the exception. | **Limited fresh PASS-19 check.** Relevant text and images at zero **0, 4, 8** inspected. No actual party’s service is adjudicated here. |\n| **S_WI-P17-S022** | Wisconsin Court of Appeals, *Midland Credit Management v. Ceron*, No. 2025AP1065, reported October 1, 2026. https://www.wicourts.gov/ca/opinion/DisplayDocument.pdf?content=pdf&seqNo=1182870 — PASS-17 reported ¶¶8–10, 15–26 and specified PDF pages | **Researcher-attributed prior read, not newly certified.** Ordinary persuasive eligibility requires verified authored-opinion status, the post-2009 issuance date, and nonpublication. The coordinator’s PDF and one public HTML alternate failed; those failures neither disprove the earlier researcher read nor verify it. | **No PASS-19 fetch or pixel inspection.** Earlier reported pages remain historical observations only. No fresh coordinator case-body, authorship, pixel, or citator certification is claimed. |\n\nThe fresh *Ryan* and *Ripco* documents visibly establish named authorship and nonpublication. Their citation eligibility does not enlarge their holdings. [Wisconsin Court System+3](https://wicourts.gov/ca/opinion/DisplayDocument.pdf?content=pdf&seqNo=240493)\n\n## 4. Remaining affected PASS-17 atomic-claim cells\n\nThe following replacements remove the three pre-2009 opinions from ordinary persuasive support. Existing statutory/currentness holds remain.\n\n| Full PASS-17 claim ID | Corrected actor/predicate/assertion and consequence | Properly qualified support | Remaining limit |\n| --- | --- | --- | --- |\n| **S_WI-P17-C006** | A reopening movant using SC-515A is asked to explain both the missed answer/appearance and why the movant could prevail. This is a form-based evidence checklist, not a new universal merits rule. | **S_WI-P17-S012**, SC-515A’s two explanation fields; attributed prior read | Form not freshly reread; statutes and local implementation remain held. |\n| **S_WI-P17-C007** | A court’s reopening decision is discretionary: the decision must consider relevant facts, apply the proper legal standard, and use a rational process. Remove Zander/Gregory as ordinary persuasive support. | **S_WI-P17-S025, Ryan ¶¶9, 11–12**, printed pp.4–5/zero 3–4; eligible persuasive authority | Ryan does not independently substantiate every factor originally collected under this claim. |\n| **S_WI-P17-C008** | The original promptness/within-the-outer-period proposition remains **attributed to the reported Ceron read**, not newly verified by this correction. | **S_WI-P17-S022**, reported ¶¶23–26 | Ceron body, authorship, and subsequent status remain unreplicated here. Do not substitute the barred pre-2009 cases. |\n| **S_WI-P17-C011** | For the neglect theory discussed in Ryan, excusable neglect is measured against a reasonably prudent person and is not merely carelessness or inattention. | **S_WI-P17-S025, Ryan ¶12**, printed p.5/zero 4 | Persuasive case-specific guidance; not a categorical rule that every missed appearance is inexcusable. |\n| **S_WI-P17-C012** | A proposed meritorious position remains relevant under the previously read SC-515A and the general §806.07(h) framework in Miller. Zander is removed as ordinary persuasive support. | **S_WI-P17-S012**; **S_WI-P17-S021, Miller ¶36**, attributed prior reads | Miller is an ordinary-civil catchall case, not an automatic chapter 799 bypass or a fresh ruling that the same factor is mandatory in every reopening case. |\n| **S_WI-P17-C013** | In Ryan, the asserted wrong-person defense did not cure the failure to challenge the lack-of-good-cause determination on appeal. | **S_WI-P17-S025, Ryan ¶¶16–19**, printed pp.5–6/zero 4–5 | Preserve appellate posture and the unchallenged/reply-related reasoning; do not turn it into a universal rejection of merits evidence. |\n| **S_WI-P17-C019** | Ryan discusses §806.07 factors as guideposts to §799.29 good cause. The preserved published Mercado ordinary-default boundary remains separate. | **S_WI-P17-S025, Ryan ¶11**; **S_WI-P17-S019, Mercado ¶¶9–14**, latter as attributed prior read | Guideposts do not make §806.07 an unrestricted alternative route. No new current statute read. |\n| **S_WI-P17-C020** | Mistake, surprise, and neglect may be considered as good-cause guideposts. Remove Zander and Gregory as ordinary persuasive authority; retain Ryan’s limited discussion. | **S_WI-P17-S025, Ryan ¶¶11–12** | A claimed emergency, notice defect, or other fact still requires separate proof. Gregory’s summary-judgment notice facts do not become a generic default rule. |\n| **S_WI-P17-C021** | The specific “unexplained delay inside twelve months can justify denial” application remains the original researcher’s Ceron attribution. | **S_WI-P17-S022**, reported ¶¶23–26 | No fresh Ceron body or image verification; no new deadline conclusion. |\n| **S_WI-P17-C026** | The late genuine-void-service exception remains unresolved in the reviewed work. Ripco assumed that exception without deciding it and affirmed on different grounds. | **S_WI-P17-S023, Ripco ¶¶2, 10–11, 15** | No blanket ruling that late motions are either always permitted or always barred; no actual service determination. |\n\nThe replacement support for the discretion and neglect propositions is visible in Ryan’s actual ¶¶9–12. Its ¶¶16–19 preserve the important appellate limitation. [Wisconsin Court System+2](https://wicourts.gov/ca/opinion/DisplayDocument.pdf?content=pdf&seqNo=240493)\n\n### Preserved supporting anchors—not fresh PASS-19 reads\n\n| Existing source | Exact retained source and pinpoint | Narrow role retained |\n| --- | --- | --- |\n| **S_WI-P17-S012** | Wisconsin Court System, SC-515A, rev. 11/19, printed p.1/zero 0. https://www.wicourts.gov/formdisplay/SC-515A.pdf?formNumber=SC-515A&formType=Form&formatId=2&language=en | Form asks why the default occurred and why the movant could win. PASS-17’s October 26 Pacific/October 27 UTC read is attributed, not refreshed. |\n| **S_WI-P17-S019** | *Mercado v. GE Money Bank*, 2009 WI App 73, ¶¶9–14. https://www.wicourts.gov/ca/opinion/DisplayDocument.html?content=html&seqNo=36141 | Published ordinary-valid-default route boundary. Not promoted to an answer to every genuine lack-of-service claim. Prior read only. |\n| **S_WI-P17-S020** | *Village of Trempealeau v. Mikrut*, 2004 WI 79, ¶¶31–38. https://www.wicourts.gov/sc/opinion/DisplayDocument.html?content=html&seqNo=16730 | Published general competency-versus-voidness distinction. Not independently a chapter 799 exception holding. Prior read only. |\n| **S_WI-P17-S021** | *Miller v. Hanover Insurance Co.*, 2010 WI 75, ¶¶34–46, especially ¶36. https://www.wicourts.gov/sc/opinion/DisplayDocument.html?content=html&seqNo=52041 | Published ordinary-civil §806.07(h) framework. Not an automatic chapter 799 bypass. Prior read only. |\n\n## 5. Exact narrative and self-check replacements\n\n### PASS-17 §8: good cause and excusable neglect\n\nThe ordinary good-cause discussion may retain Ryan’s eligible, nonbinding discussion of discretion and excusable neglect at ¶¶9–12. Zander and Gregory are removed as ordinary persuasive authorities. The original promptness discussion attributed to Ceron remains a separately labeled prior researcher read, not newly verified in this correction. No general medical-emergency, notice-defect, or meritorious-defense outcome is established merely by removing the citation defect.\n\n### PASS-17 §12: genuine voidness\n\nBenitez is retained only as a historical 1998 research read; it is not an ordinary persuasive authority available under Rule 809.23(3)(b), and its historical six-month text is not current law. Ripco is an eligible authored post-2009 unpublished opinion, but it assumed without deciding the alleged void-service exception. Mercado’s ordinary-default boundary, Mikrut’s general voidness distinction, and the unresolved chapter 799 interaction remain separate.\n\n### PASS-17 §26: case-grid status sentence\n\nUnpublished opinions must be classified individually. Benitez, Zander, and Gregory are pre-July 1, 2009 historical reads, not generally citable for persuasion. Ryan and Ripco satisfy the observed authored/post-2009/nonpublication predicates and are nonbinding persuasive sources within their holdings. Ceron’s body, authorship, and images remain separately attributed to the original researcher’s reported access, without fresh coordinator or PASS-19 certification.\n\n### PASS-17 final self-check\n\nThe original reported reads remain in the raw record. PASS-19 does not retroactively change which materials PASS-17 said it read. It changes their permissible authority labels and support allocation. PASS-19 freshly read the rule order and official guide, made one unsuccessful integrated-rule request, and narrowly rechecked the existing Ryan and Ripco opinion sources. It did not freshly access Benitez, Zander, Gregory, Ceron, the underlying court records, or the general reopening statutes. No complete citator or independent review was performed.\n\n## 6. New citation-rule source register\n\nThese are the **only newly registered PASS-19 resources**. Ryan and Ripco retain their original PASS-17 IDs rather than being counted again as new authorities.\n\n| Source ID | Issuer/title and full literal URL | Pinpoint, version, commencement | Fresh access and read limit |\n| --- | --- | --- | --- |\n| **S_WI-P19-S001** | Wisconsin Supreme Court, **2009 WI 2, Rule Order No. 08-02**. https://www.wicourts.gov/sc/scord/DisplayDocument.html?content=html&seqNo=35116 | §§1–3: Rule 809.23(3)(a)–(c); entered January 6, 2009; effective **July 1, 2009**. HTML; printed-page/PDF index not applicable | **Fresh full relevant order body read**, October 26 Pacific/October 27 UTC. Posted order contains an editing notice. Not a full 2026 amendment-chain certification. [Wisconsin Court System](https://www.wicourts.gov/sc/scord/DisplayDocument.html?content=html&seqNo=35116) |\n| **S_WI-P19-S002** | Wisconsin Court System, **Court of Appeals opinions guide**. https://www.wicourts.gov/opinions/appeals2.htm | “Precedential value of opinions”; “Citation of unpublished opinions.” No authoritative legal-effective date supplied by the webpage | **Fresh relevant guidance body read**, same access dates. Current accessibility is not proof that every page detail was updated in 2026. [Wisconsin Court System](https://www.wicourts.gov/opinions/appeals2.htm) |\n| **S_WI-P19-S003** | Wisconsin Legislature, **Rule 809.23(3), integrated statute endpoint**. https://docs.legis.wisconsin.gov/statutes/statutes/809/iii/23/3 | Intended current paragraphs (a)–(c) | **One fresh failed fetch: timeout**, same access dates. No integrated body read; no repeated retry or workaround. (Invalid URL) |\n\n**New resource rows: 3—two successful body reads and one failed current-body route.**\n\n## 7. New atomic correction claims\n\n| Claim ID | A066/A097/A098 status | Actor/predicate | Corrected act or effect | Source/pinpoint | Exception or hold |\n| --- | --- | --- | --- | --- | --- |\n| **S_WI-P19-C001** | Open | Party considering an unpublished Wisconsin opinion | General citation bar applies, subject to the three specified preclusion/law-of-case purposes and paragraph (b) | S001 §1, Rule 809.23(3)(a) | No exception predicate supplied for the three old cases |\n| **C002** | Open | Party using a post-cutoff authored opinion | July 1, 2009-or-later authored panel/single-judge opinion can qualify for persuasive citation | S001 §2, (3)(b) | Date alone is insufficient |\n| **C003** | Open | Per curiam, memorandum, summary disposition, or other order | These formats do not qualify as authored opinions under paragraph (b) | S001 §2 | Paragraph (a)’s limited purposes remain distinct |\n| **C004** | Open | Court and litigant | Eligible unpublished opinion is nonbinding; court need not discuss it; party need not research or cite it | S001 §2 | Persuasiveness is not precedential force |\n| **C005** | Open | Party actually citing an unpublished opinion | File and serve a copy with the citing brief or paper | S001 §3, (3)(c) | No paper was prepared or filed here |\n| **C006** | Open | Researcher verifying current law | Order effective July 1, 2009; official guide corroborates distinction; current integrated body remains unread | S001–S003 | No complete 2026 amendment-chain certification |\n| **C007** | Open | Use of Benitez, Zander, Gregory | Retain historical reads; withdraw ordinary persuasive-authority classification | C001–C003 applied to supplied P17 dates/status | Historical reasoning is not declared false |\n| **C008** | Open | Use of Ryan | Authorship, single-judge status, date, and nonpublication were narrowly rechecked; propositions remain case-specific | Existing S_WI-P17-S025, ¶1/fn.1, ¶¶9–12, 16–19 | No full subsequent-history review |\n| **C009** | Open | Use of Ripco | Eligible persuasive status does not turn an assumed voidness exception into a holding | Existing S_WI-P17-S023, ¶¶2, 10–11, 15 | Genuine void-small-claims exception remains unresolved |\n| **C010** | Open | Use of Ceron | Prior researcher body/image claims remain separate from failed coordinator access and from PASS-19 | Supplied review record; existing S_WI-P17-S022 | No new body, pixel, authorship, or citator certification |\n| **C011** | Open | P17 claim-support audit | Remove barred authorities from dependent claims; retain only qualified support or an explicit hold | Replacement tables above | No new reopening, deadline, remedy, or merits conclusion |\n\n**New correction claims: 11.**\n\n## 8. Complete affected PASS-17 coverage replacements\n\nThese are **17 existing coverage rows**, not new coverage added to the original 139-row history.\n\n| Original P17 coverage row | Replacement status/finding | Corrected claim support | Exact remaining gap |\n| --- | --- | --- | --- |\n| **7 — Good cause** | Supported only within qualified sources; remove Zander/Gregory persuasive labels | P17-C007; P19-C008/C011; Ryan ¶¶9, 11–12 | Broader factor list is not newly certified |\n| **22 — Excusable neglect** | Ryan supplies eligible, nonbinding prudent-person discussion | P17-C011/C020; P19-C008 | Actual circumstances and current statutory application |\n| **23 — Forgetfulness** | Retain Ryan as a limited factual illustration, not a universal rule | P17-C011/C013; Ryan ¶¶16–19 | Merits and appellate-posture differences |\n| **24 — Medical/emergency problem** | Hypothetical possibility only; no categorical result from Gregory | P17-C020; P19-C011 | Actual proof and properly applicable authority |\n| **25 — Meritorious defense** | Retain form and general Miller factor, with scope limits | P17-C006/C012; P17-S012/S021 | No universal chapter 799 requirement newly established |\n| **26 — Defense alone** | Retain Ryan’s actual appellate reasoning | P17-C013; P19-C008 | Does not bar every merits-based reopening request |\n| **27 — Promptness** | Retained as attributed prior Ceron discussion | P17-C008/C021; P19-C010 | Ceron body/authorship/current status not freshly replicated |\n| **28 — Delay within one year** | Same attributed-source limitation; no new clock ruling | P17-C008/C021; P19-C010 | Fresh competent support needed before status upgrade |\n| **37 — Invalid service after twelve months** | **Unresolved**; Ripco assumed without deciding | P17-C026; P19-C009 | Controlling applicable authority and actual service facts |\n| **38 — Personal-jurisdiction proof** | Merits not adjudicated; Benitez is not ordinary persuasive support | P17-C027; P19-C007/C009 | Actual service record, waiver, and governing rules |\n| **86 — Ceron** | Historical researcher-attributed read; conditional citation eligibility, no fresh certification | P19-C010 | Authored/nonpublication status and body replication |\n| **87 — Ripco** | Eligible authored unpublished opinion; narrow nonholding preserved | P19-C002/C009 | Full later treatment not checked |\n| **88 — Benitez** | **Historical only**, except any independently established Rule (3)(a) use | P17-C027; P19-C001/C007 | No preclusion or law-of-case facts supplied |\n| **89 — Ryan** | Eligible authored unpublished opinion, nonbinding | P19-C002/C008 | Complete subsequent history not checked |\n| **90 — Zander** | **Historical only**, not ordinary persuasive support | P19-C001/C007/C011 | Use a permissible authority for any proposed court proposition |\n| **91 — Gregory** | **Historical only**; preserve summary-judgment-notice posture | P19-C001/C007/C011 | Do not generalize to default or emergency relief |\n| **92 — Complete citator** | Remains **not performed** | P17-C051; P19-C006/C010 | Separate citator work required |\n\n## 9. Old-to-new crosswalk\n\n| # | PASS-17 item | PASS-19 change | Source/claim link |\n| --- | --- | --- | --- |\n| 1 | C050 blanket unpublished-opinion statement | Replace with date/authorship/format/purpose test | P19-C001–C006 |\n| 2 | C027 Benitez support | Historical attribution only; remove ordinary persuasive role | P19-C007/C009 |\n| 3 | S024 and Benitez case-grid row | Add pre-2009 citation bar, obsolete six-month text, unresolved modern issue | P17-S024; P19-C007 |\n| 4 | S026 and Zander case-grid row | Historical-only status; remove from ordinary good-cause support | P19-C007/C011 |\n| 5 | S027 and Gregory case-grid row | Historical-only status; preserve summary-judgment notice posture | P19-C007/C011 |\n| 6 | C006/C007 | Retain SC-515A’s request; re-anchor discretion to Ryan | P17-S012/S025 |\n| 7 | C011/C020 | Re-anchor neglect discussion to Ryan; delete Zander/Gregory support | P19-C008/C011 |\n| 8 | C012 | Retain form/Miller support within their actual scope | P17-S012/S021 |\n| 9 | C013 | Retain only Ryan’s case-specific appellate reasoning | P17-S025 ¶¶16–19 |\n| 10 | C008/C019/C021 and S022 | Separate verified Ryan guidepost discussion from attributed Ceron promptness assertions | P19-C008/C010 |\n| 11 | C026 and S023 | Preserve Ripco’s assumed-without-deciding limit | P19-C009 |\n| 12 | S025 and Ryan case-grid row | Add narrowly verified date, authorship, nonpublication, and pinpoints | P19-C008 |\n| 13 | Coverage rows listed in §8 | Apply the 17 replacement statuses without adding original coverage rows | P19-C001–C011 |\n| 14 | Narratives §§8, 12, 26; original workflows 1, 2, 3, 5 | Citation/support annotations only; no workflow or deadline recalculation | Replacements in §§4–5 |\n| 15 | Final self-check and raw provenance | Separate historical reads, fresh limited checks, coordinator failures, and unresolved holds | §§3, 5–6 and final audit |\n\n**Crosswalk rows: 15.**\n\n## 10. Two fictional citation-routing examples\n\n### Example A — Historical 1998 unpublished opinion\n\nA hypothetical researcher proposes citing *Benitez* in a new, unrelated Wisconsin consumer-debt case to establish that a late motion alleging defective service is always permitted.\n\n**Routing result:** Do not use the 1998 unpublished opinion as ordinary persuasive authority. Its historical read may remain in the research notes, but Rule 809.23(3)(b)’s date requirement is not met. **P19-C001/C007.** [Wisconsin Court System](https://www.wicourts.gov/sc/scord/DisplayDocument.html?content=html&seqNo=35116)\n\n**Possible exception:** If the opinion were relevant to claim preclusion, issue preclusion, or law of the case, paragraph (a) would require a separate analysis of that purpose. No such relationship is assumed.\n\n**Adverse branch:** Changing the label to “persuasive only,” omitting the case name while attributing its judicial conclusion, or using its old six-month text does not establish a current general reopening rule.\n\n**Missing facts/authority:** Any actual preclusion relationship, the current applicable statute, properly qualified controlling authority, and service facts. No filing or service outcome is determined.\n\n### Example B — Authored 2019 unpublished opinion\n\nA hypothetical researcher considers *Ryan v. Friday*, No. 2018AP1354, for a Wisconsin memorandum addressing a failure to attend a small-claims hearing.\n\nThe official opinion is dated May 14, 2019, identifies **Dugan, J.** as the author under §752.31(2)(a), and states it will not be published. It therefore fits the observed date/authorship category for persuasive citation. **P19-C002/C008.** [Wisconsin Court System+1](https://wicourts.gov/ca/opinion/DisplayDocument.pdf?content=pdf&seqNo=240493)\n\nIts use must remain limited: ¶¶9–12 discuss discretion and neglect, while ¶¶16–19 preserve the actual appeal’s failure to challenge the good-cause reasoning. It does not prove that every forgetful litigant loses or that a proposed defense is irrelevant in every case.\n\nIf actually cited, the party would file and serve a copy with the citing paper; the court need not discuss or follow it. The guide’s caption/case-number/unpublished/date/pinpoint format should be used, not a table-only public-domain citation. **P19-C004–C006.** [Wisconsin Court System+1](https://www.wicourts.gov/sc/scord/DisplayDocument.html?content=html&seqNo=35116)\n\n**Remaining limit:** Later treatment and the actual matter’s facts are not reviewed. No brief was prepared or filed.\n\n## 11. Complete correction-scope coverage\n\n| # | Correction issue | Status | Claims/evidence | Exact limit or next check |\n| --- | --- | --- | --- | --- |\n| 1 | General unpublished citation prohibition | Answered from official order | C001; S001 §1 | Current integrated body held |\n| 2 | Claim/issue preclusion and law-of-case exceptions | Answered | C001; S001 §1 | No actual exception facts |\n| 3 | July 1, 2009 cutoff | Answered | C002; S001 §2; S002 | Issuance date matters |\n| 4 | Authored panel or §752.31(2) single-judge requirement | Answered | C002 | Status must be verified |\n| 5 | Per curiam/memorandum/summary/other-order exclusions | Answered | C003 | Date alone insufficient |\n| 6 | Nonbinding status | Answered | C004 | No controlling precedent |\n| 7 | Court need not discuss/distinguish | Answered | C004 | Persuasive use remains discretionary |\n| 8 | Party need not research/cite | Answered | C004 | No duty manufactured |\n| 9 | File-and-serve copy requirement | Answered | C005 | No citation filing performed |\n| 10 | Official guide citation format | Answered as guidance | C006; S002 | Not an amendment |\n| 11 | 2009 order’s effective date | Answered | C006; S001 | Not full 2026 amendment chain |\n| 12 | Current integrated Rule 809.23(3) body | Unresolved | S003 | One failed fetch; no loop |\n| 13 | Benitez classification | Corrected | C007 | Historical six-month text not current deadline |\n| 14 | Zander classification | Corrected | C007 | Removed from ordinary persuasive support |\n| 15 | Gregory classification/posture | Corrected | C007 | Summary-judgment notice context retained |\n| 16 | Ryan authorship/date/nonpublication | Narrowly verified | C008; existing P17-S025 | No full citator |\n| 17 | Ripco authorship/date/nonpublication and nonholding | Narrowly verified | C009; existing P17-S023 | Voidness exception not decided |\n| 18 | Ceron attribution | Preserved with qualification | C010 | No fresh body/pixels/authorship certification |\n| 19 | Dependent P17 claims | Repaired or explicitly held | C011; §4 | No reliance on barred old opinions as ordinary authority |\n| 20 | Genuine void-small-claims exception and published anchors | Unresolved/bounds preserved | C009/C011; retained P17-S019–S021 | No new service-validity or bypass conclusion |\n\n**Correction-core rows: 20.**\n\n## 12. Retained holds and territorial limits\n\n### Deferred holds\n\n| # | Hold retained | PASS-19 effect |\n| --- | --- | --- |\n| D1 | Complete current §§799.29, 799.14, 801.14, 801.15, and 806.07 bodies | No new statute-body certification |\n| D2 | Meaning of “notice of motion made,” filing/service completion, electronic cutoffs, closure adjustments | No deadline recalculation or operational ruling |\n| D3 | Full subsequent history and citator treatment of all retained cases | No all-case certification |\n| D4 | Actual service, appearance, waiver, jurisdiction, judgment validity, and private facts | No individualized conclusion |\n| D5 | PASS-16, PASS-18, and other unreviewed modules | No findings adopted |\n| D6 | Remedies, fees, publication, operations, component, state, A066/A097/A098, and parent acceptance | Remain unaccepted |\n\n**Deferred rows: 6.**\n\n### Territorial and local scope\n\n| # | Scope | Limit |\n| --- | --- | --- |\n| T1 | Wisconsin courts | The citation rule concerns courts of this state. All 72 counties’ local filing, service, hearing, and electronic-copy implementation remain unexamined. |\n| T2 | Federal courts | No federal citation or Erie rule is imported from Rule 809.23. |\n| T3 | Tribal courts, other states, and foreign jurisdictions | No citation rule or procedural permission is determined. |\n\n**Territorial/local rows: 3.**\n\n## 13. Final provenance and count reconciliation\n\n| Unit | Count/status |\n| --- | --- |\n| New PASS-19 citation-rule resource rows | **3** |\n| Successfully read new rule/guidance bodies | **2** |\n| Failed new integrated-rule route | **1** |\n| Existing PASS-17 opinion sources narrowly rechecked | **2 — Ryan and Ripco; original IDs retained** |\n| PASS-17 source/case-grid status overlays | **6** |\n| Additional previously read supporting anchors identified | **4 — not freshly reread** |\n| New PASS-19 atomic correction claims | **11** |\n| PASS-17 claim replacements | **12 — C006, C007, C008, C011, C012, C013, C019, C020, C021, C026, C027, C050** |\n| Existing PASS-17 coverage rows patched | **17** |\n| PASS-19 correction-core rows | **20** |\n| Old-to-new crosswalk rows | **15** |\n| New fictional citation-routing examples | **2** |\n| Retained deferred rows | **6** |\n| Territorial/local rows | **3** |\n\nThe supplied original PASS-17 totals—**28 sources, 53 claims, 139 coverage rows, and 18 workflows**—remain historical record totals, not new law counts or independently recounted DOM totals.\n\n### Researcher self-check\n\nThe newly read legal-rule materials were the official 2009 WI 2 order and the official Court of Appeals guide. The current integrated rule fetch failed once. Ryan and Ripco were opened only for the limited source-status and dependent-claim checks described above; no underlying docket or party record was searched. Benitez, Zander, Gregory, Ceron, and the general reopening statutes were not freshly reopened.\n\nThe coordinator’s supplied completion timestamp and packet references are review metadata, not source-opening clocks. The reported Ceron researcher read, failed coordinator routes, and absence of a fresh PASS-19 read remain distinct.\n\nNo original workflow calendar was recalculated. No motion, brief, citation filing, service, contact, complaint, record request, purchase, account action, local coordinator-file write, or publication occurred.\n\n**The correction changes source eligibility and support—not historical outcomes, actual judgment validity, or the unresolved void-small-claims question. It is not independent review, all-source certification, or Wisconsin/component/parent acceptance.**\n\nEND S_WI PASS-19\n\n","tables":[{"headers":["Provision","Rule established by the order"],"index":0,"links":[],"row_links":[[],[],[],[],[],[]],"rows":[["Provision","Rule established by the order"],["(3)(a)","Unpublished opinions ordinarily cannot be cited in Wisconsin courts as precedent or authority. The specified exceptions are claim preclusion, issue preclusion, and law of the case, together with the separate permission in paragraph (b)."],["(3)(b): date and authorship","Persuasive citation is permitted for an unpublished opinion issued on or after July 1, 2009, authored by a member of a three-judge panel or by a single judge under §752.31(2)."],["(3)(b): excluded formats","Per curiam opinions, memorandum opinions, summary-disposition orders, and other orders do not qualify as authored opinions for this permission."],["(3)(b): legal weight","A qualifying opinion is not binding precedent. A court need not distinguish or discuss it; a party need not research or cite it."],["(3)(c)","A party actually citing an unpublished opinion must file and serve a copy with the brief or other paper containing the citation."]]},{"headers":["Existing source ID","Official document and exact URL","Corrected citation status and substantive limit","Access attribution"],"index":1,"links":[],"row_links":[[],[],[],[],[],[],[]],"rows":[["Existing source ID","Official document and exact URL","Corrected citation status and substantive limit","Access attribution"],["S_WI-P17-S024","Wisconsin Court of Appeals, Benitez v. Fasick, No. 97-3572, May 27, 1998. https://www.wicourts.gov/ca/opinion/DisplayDocument.html?content=html&seqNo=13362 — unnumbered discussion of §§799.29 and 806.07(d); HTML, PDF indexes not applicable","Historical research only; not generally citable for persuasion. Limited Rule 809.23(3)(a) exceptions are not established. The historical six-month provision is obsolete for current-deadline purposes. Does not resolve the modern small-claims void-service exception.","PASS-17 reported body read on October 26 Pacific/October 27 UTC. Not reopened in PASS-19. Historical detail and six-month qualification are separately attributed to the supplied record/review."],["S_WI-P17-S026","Wisconsin Court of Appeals, Zander Solutions v. Koenigs, No. 04-0764, October 28, 2004. https://www.wicourts.gov/ca/opinion/DisplayDocument.html?content=html&seqNo=7390 — ¶¶5–8; HTML","Historical research only; not generally citable for persuasion. Its mailed-answer/neglect discussion is removed as ordinary persuasive support for C007, C011, C012, and C020. No finding that its historical doctrine was false.","PASS-17 reported body read on October 26 Pacific/October 27 UTC. Not reopened in PASS-19."],["S_WI-P17-S027","Wisconsin Court of Appeals, Gregory v. United Parcel Service, No. 98-3024, September 29, 1999. https://www.wicourts.gov/ca/opinion/DisplayDocument.html?content=html&seqNo=14670 — unnumbered notice discussion; HTML","Historical research only; not generally citable for persuasion. Retain the summary-judgment-motion notice posture; do not convert it into a general default-judgment or medical-emergency rule.","PASS-17 reported body read on October 26 Pacific/October 27 UTC. Not reopened in PASS-19."],["S_WI-P17-S025","Wisconsin Court of Appeals, Ryan v. Friday, No. 2018AP1354, May 14, 2019. https://wicourts.gov/ca/opinion/DisplayDocument.pdf?content=pdf&seqNo=240493 — ¶1 and footnote 1; ¶¶9–12, 16–19; first page unnumbered/zero 0; printed pp.4–6/zero 3–5","Eligible authored post-2009 unpublished opinion; persuasive, not binding. The opinion identifies Dugan, J., acting under §752.31(2)(a), and states it will not be published. Retain only the actual discretion, excusable-neglect, and appellate-posture propositions.","Limited fresh PASS-19 check. Text and images at zero indexes 0, 3, 4, 5 inspected. No subsequent-history or complete-citator certification."],["S_WI-P17-S023","Wisconsin Court of Appeals, Ripco Credit Union v. Kennedy, No. 2015AP1280, February 23, 2016. https://www.wicourts.gov/ca/opinion/DisplayDocument.pdf?content=pdf&seqNo=162063 — ¶1/footnote 1; ¶¶2, 9–11, 15; first page unnumbered/zero 0; printed p.5/zero 4; printed p.9/zero 8","Eligible authored post-2009 unpublished opinion; persuasive, not binding. Hruz, J., decided it under §752.31(2). It assumed without deciding the late void-judgment exception and resolved that appeal on its service facts. It did not establish the exception.","Limited fresh PASS-19 check. Relevant text and images at zero 0, 4, 8 inspected. No actual party’s service is adjudicated here."],["S_WI-P17-S022","Wisconsin Court of Appeals, Midland Credit Management v. Ceron, No. 2025AP1065, reported October 1, 2026. https://www.wicourts.gov/ca/opinion/DisplayDocument.pdf?content=pdf&seqNo=1182870 — PASS-17 reported ¶¶8–10, 15–26 and specified PDF pages","Researcher-attributed prior read, not newly certified. Ordinary persuasive eligibility requires verified authored-opinion status, the post-2009 issuance date, and nonpublication. The coordinator’s PDF and one public HTML alternate failed; those failures neither disprove the earlier researcher read nor verify it.","No PASS-19 fetch or pixel inspection. Earlier reported pages remain historical observations only. No fresh coordinator case-body, authorship, pixel, or citator certification is claimed."]]},{"headers":["Full PASS-17 claim ID","Corrected actor/predicate/assertion and consequence","Properly qualified support","Remaining limit"],"index":2,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Full PASS-17 claim ID","Corrected actor/predicate/assertion and consequence","Properly qualified support","Remaining limit"],["S_WI-P17-C006","A reopening movant using SC-515A is asked to explain both the missed answer/appearance and why the movant could prevail. This is a form-based evidence checklist, not a new universal merits rule.","S_WI-P17-S012, SC-515A’s two explanation fields; attributed prior read","Form not freshly reread; statutes and local implementation remain held."],["S_WI-P17-C007","A court’s reopening decision is discretionary: the decision must consider relevant facts, apply the proper legal standard, and use a rational process. Remove Zander/Gregory as ordinary persuasive support.","S_WI-P17-S025, Ryan ¶¶9, 11–12, printed pp.4–5/zero 3–4; eligible persuasive authority","Ryan does not independently substantiate every factor originally collected under this claim."],["S_WI-P17-C008","The original promptness/within-the-outer-period proposition remains attributed to the reported Ceron read, not newly verified by this correction.","S_WI-P17-S022, reported ¶¶23–26","Ceron body, authorship, and subsequent status remain unreplicated here. Do not substitute the barred pre-2009 cases."],["S_WI-P17-C011","For the neglect theory discussed in Ryan, excusable neglect is measured against a reasonably prudent person and is not merely carelessness or inattention.","S_WI-P17-S025, Ryan ¶12, printed p.5/zero 4","Persuasive case-specific guidance; not a categorical rule that every missed appearance is inexcusable."],["S_WI-P17-C012","A proposed meritorious position remains relevant under the previously read SC-515A and the general §806.07(h) framework in Miller. Zander is removed as ordinary persuasive support.","S_WI-P17-S012; S_WI-P17-S021, Miller ¶36, attributed prior reads","Miller is an ordinary-civil catchall case, not an automatic chapter 799 bypass or a fresh ruling that the same factor is mandatory in every reopening case."],["S_WI-P17-C013","In Ryan, the asserted wrong-person defense did not cure the failure to challenge the lack-of-good-cause determination on appeal.","S_WI-P17-S025, Ryan ¶¶16–19, printed pp.5–6/zero 4–5","Preserve appellate posture and the unchallenged/reply-related reasoning; do not turn it into a universal rejection of merits evidence."],["S_WI-P17-C019","Ryan discusses §806.07 factors as guideposts to §799.29 good cause. The preserved published Mercado ordinary-default boundary remains separate.","S_WI-P17-S025, Ryan ¶11; S_WI-P17-S019, Mercado ¶¶9–14, latter as attributed prior read","Guideposts do not make §806.07 an unrestricted alternative route. No new current statute read."],["S_WI-P17-C020","Mistake, surprise, and neglect may be considered as good-cause guideposts. Remove Zander and Gregory as ordinary persuasive authority; retain Ryan’s limited discussion.","S_WI-P17-S025, Ryan ¶¶11–12","A claimed emergency, notice defect, or other fact still requires separate proof. Gregory’s summary-judgment notice facts do not become a generic default rule."],["S_WI-P17-C021","The specific “unexplained delay inside twelve months can justify denial” application remains the original researcher’s Ceron attribution.","S_WI-P17-S022, reported ¶¶23–26","No fresh Ceron body or image verification; no new deadline conclusion."],["S_WI-P17-C026","The late genuine-void-service exception remains unresolved in the reviewed work. Ripco assumed that exception without deciding it and affirmed on different grounds.","S_WI-P17-S023, Ripco ¶¶2, 10–11, 15","No blanket ruling that late motions are either always permitted or always barred; no actual service determination."]]},{"headers":["Existing source","Exact retained source and pinpoint","Narrow role retained"],"index":3,"links":[],"row_links":[[],[],[],[],[]],"rows":[["Existing source","Exact retained source and pinpoint","Narrow role retained"],["S_WI-P17-S012","Wisconsin Court System, SC-515A, rev. 11/19, printed p.1/zero 0. https://www.wicourts.gov/formdisplay/SC-515A.pdf?formNumber=SC-515A&formType=Form&formatId=2&language=en","Form asks why the default occurred and why the movant could win. PASS-17’s October 26 Pacific/October 27 UTC read is attributed, not refreshed."],["S_WI-P17-S019","Mercado v. GE Money Bank, 2009 WI App 73, ¶¶9–14. https://www.wicourts.gov/ca/opinion/DisplayDocument.html?content=html&seqNo=36141","Published ordinary-valid-default route boundary. Not promoted to an answer to every genuine lack-of-service claim. Prior read only."],["S_WI-P17-S020","Village of Trempealeau v. Mikrut, 2004 WI 79, ¶¶31–38. https://www.wicourts.gov/sc/opinion/DisplayDocument.html?content=html&seqNo=16730","Published general competency-versus-voidness distinction. Not independently a chapter 799 exception holding. Prior read only."],["S_WI-P17-S021","Miller v. Hanover Insurance Co., 2010 WI 75, ¶¶34–46, especially ¶36. https://www.wicourts.gov/sc/opinion/DisplayDocument.html?content=html&seqNo=52041","Published ordinary-civil §806.07(h) framework. Not an automatic chapter 799 bypass. Prior read only."]]},{"headers":["Source ID","Issuer/title and full literal URL","Pinpoint, version, commencement","Fresh access and read limit"],"index":4,"links":[{"href":"https://www.wicourts.gov/sc/scord/DisplayDocument.html?content=html&seqNo=35116","text":"Wisconsin Court System"},{"href":"https://www.wicourts.gov/opinions/appeals2.htm","text":"Wisconsin Court System"}],"row_links":[[],[{"href":"https://www.wicourts.gov/sc/scord/DisplayDocument.html?content=html&seqNo=35116","text":"Wisconsin Court System"}],[{"href":"https://www.wicourts.gov/opinions/appeals2.htm","text":"Wisconsin Court System"}],[]],"rows":[["Source ID","Issuer/title and full literal URL","Pinpoint, version, commencement","Fresh access and read limit"],["S_WI-P19-S001","Wisconsin Supreme Court, 2009 WI 2, Rule Order No. 08-02. https://www.wicourts.gov/sc/scord/DisplayDocument.html?content=html&seqNo=35116","§§1–3: Rule 809.23(3)(a)–(c); entered January 6, 2009; effective July 1, 2009. HTML; printed-page/PDF index not applicable","Fresh full relevant order body read, October 26 Pacific/October 27 UTC. Posted order contains an editing notice. Not a full 2026 amendment-chain certification. \nWisconsin Court System"],["S_WI-P19-S002","Wisconsin Court System, Court of Appeals opinions guide. https://www.wicourts.gov/opinions/appeals2.htm","“Precedential value of opinions”; “Citation of unpublished opinions.” No authoritative legal-effective date supplied by the webpage","Fresh relevant guidance body read, same access dates. Current accessibility is not proof that every page detail was updated in 2026. \nWisconsin Court System"],["S_WI-P19-S003","Wisconsin Legislature, Rule 809.23(3), integrated statute endpoint. https://docs.legis.wisconsin.gov/statutes/statutes/809/iii/23/3","Intended current paragraphs (a)–(c)","One fresh failed fetch: timeout, same access dates. No integrated body read; no repeated retry or workaround. (Invalid URL)"]]},{"headers":["Claim ID","A066/A097/A098 status","Actor/predicate","Corrected act or effect","Source/pinpoint","Exception or hold"],"index":5,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Claim ID","A066/A097/A098 status","Actor/predicate","Corrected act or effect","Source/pinpoint","Exception or hold"],["S_WI-P19-C001","Open","Party considering an unpublished Wisconsin opinion","General citation bar applies, subject to the three specified preclusion/law-of-case purposes and paragraph (b)","S001 §1, Rule 809.23(3)(a)","No exception predicate supplied for the three old cases"],["C002","Open","Party using a post-cutoff authored opinion","July 1, 2009-or-later authored panel/single-judge opinion can qualify for persuasive citation","S001 §2, (3)(b)","Date alone is insufficient"],["C003","Open","Per curiam, memorandum, summary disposition, or other order","These formats do not qualify as authored opinions under paragraph (b)","S001 §2","Paragraph (a)’s limited purposes remain distinct"],["C004","Open","Court and litigant","Eligible unpublished opinion is nonbinding; court need not discuss it; party need not research or cite it","S001 §2","Persuasiveness is not precedential force"],["C005","Open","Party actually citing an unpublished opinion","File and serve a copy with the citing brief or paper","S001 §3, (3)(c)","No paper was prepared or filed here"],["C006","Open","Researcher verifying current law","Order effective July 1, 2009; official guide corroborates distinction; current integrated body remains unread","S001–S003","No complete 2026 amendment-chain certification"],["C007","Open","Use of Benitez, Zander, Gregory","Retain historical reads; withdraw ordinary persuasive-authority classification","C001–C003 applied to supplied P17 dates/status","Historical reasoning is not declared false"],["C008","Open","Use of Ryan","Authorship, single-judge status, date, and nonpublication were narrowly rechecked; propositions remain case-specific","Existing S_WI-P17-S025, ¶1/fn.1, ¶¶9–12, 16–19","No full subsequent-history review"],["C009","Open","Use of Ripco","Eligible persuasive status does not turn an assumed voidness exception into a holding","Existing S_WI-P17-S023, ¶¶2, 10–11, 15","Genuine void-small-claims exception remains unresolved"],["C010","Open","Use of Ceron","Prior researcher body/image claims remain separate from failed coordinator access and from PASS-19","Supplied review record; existing S_WI-P17-S022","No new body, pixel, authorship, or citator certification"],["C011","Open","P17 claim-support audit","Remove barred authorities from dependent claims; retain only qualified support or an explicit hold","Replacement tables above","No new reopening, deadline, remedy, or merits conclusion"]]},{"headers":["Original P17 coverage row","Replacement status/finding","Corrected claim support","Exact remaining gap"],"index":6,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Original P17 coverage row","Replacement status/finding","Corrected claim support","Exact remaining gap"],["7 — Good cause","Supported only within qualified sources; remove Zander/Gregory persuasive labels","P17-C007; P19-C008/C011; Ryan ¶¶9, 11–12","Broader factor list is not newly certified"],["22 — Excusable neglect","Ryan supplies eligible, nonbinding prudent-person discussion","P17-C011/C020; P19-C008","Actual circumstances and current statutory application"],["23 — Forgetfulness","Retain Ryan as a limited factual illustration, not a universal rule","P17-C011/C013; Ryan ¶¶16–19","Merits and appellate-posture differences"],["24 — Medical/emergency problem","Hypothetical possibility only; no categorical result from Gregory","P17-C020; P19-C011","Actual proof and properly applicable authority"],["25 — Meritorious defense","Retain form and general Miller factor, with scope limits","P17-C006/C012; P17-S012/S021","No universal chapter 799 requirement newly established"],["26 — Defense alone","Retain Ryan’s actual appellate reasoning","P17-C013; P19-C008","Does not bar every merits-based reopening request"],["27 — Promptness","Retained as attributed prior Ceron discussion","P17-C008/C021; P19-C010","Ceron body/authorship/current status not freshly replicated"],["28 — Delay within one year","Same attributed-source limitation; no new clock ruling","P17-C008/C021; P19-C010","Fresh competent support needed before status upgrade"],["37 — Invalid service after twelve months","Unresolved; Ripco assumed without deciding","P17-C026; P19-C009","Controlling applicable authority and actual service facts"],["38 — Personal-jurisdiction proof","Merits not adjudicated; Benitez is not ordinary persuasive support","P17-C027; P19-C007/C009","Actual service record, waiver, and governing rules"],["86 — Ceron","Historical researcher-attributed read; conditional citation eligibility, no fresh certification","P19-C010","Authored/nonpublication status and body replication"],["87 — Ripco","Eligible authored unpublished opinion; narrow nonholding preserved","P19-C002/C009","Full later treatment not checked"],["88 — Benitez","Historical only, except any independently established Rule (3)(a) use","P17-C027; P19-C001/C007","No preclusion or law-of-case facts supplied"],["89 — Ryan","Eligible authored unpublished opinion, nonbinding","P19-C002/C008","Complete subsequent history not checked"],["90 — Zander","Historical only, not ordinary persuasive support","P19-C001/C007/C011","Use a permissible authority for any proposed court proposition"],["91 — Gregory","Historical only; preserve summary-judgment-notice posture","P19-C001/C007/C011","Do not generalize to default or emergency relief"],["92 — Complete citator","Remains not performed","P17-C051; P19-C006/C010","Separate citator work required"]]},{"headers":["#","PASS-17 item","PASS-19 change","Source/claim link"],"index":7,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["#","PASS-17 item","PASS-19 change","Source/claim link"],["1","C050 blanket unpublished-opinion statement","Replace with date/authorship/format/purpose test","P19-C001–C006"],["2","C027 Benitez support","Historical attribution only; remove ordinary persuasive role","P19-C007/C009"],["3","S024 and Benitez case-grid row","Add pre-2009 citation bar, obsolete six-month text, unresolved modern issue","P17-S024; P19-C007"],["4","S026 and Zander case-grid row","Historical-only status; remove from ordinary good-cause support","P19-C007/C011"],["5","S027 and Gregory case-grid row","Historical-only status; preserve summary-judgment notice posture","P19-C007/C011"],["6","C006/C007","Retain SC-515A’s request; re-anchor discretion to Ryan","P17-S012/S025"],["7","C011/C020","Re-anchor neglect discussion to Ryan; delete Zander/Gregory support","P19-C008/C011"],["8","C012","Retain form/Miller support within their actual scope","P17-S012/S021"],["9","C013","Retain only Ryan’s case-specific appellate reasoning","P17-S025 ¶¶16–19"],["10","C008/C019/C021 and S022","Separate verified Ryan guidepost discussion from attributed Ceron promptness assertions","P19-C008/C010"],["11","C026 and S023","Preserve Ripco’s assumed-without-deciding limit","P19-C009"],["12","S025 and Ryan case-grid row","Add narrowly verified date, authorship, nonpublication, and pinpoints","P19-C008"],["13","Coverage rows listed in §8","Apply the 17 replacement statuses without adding original coverage rows","P19-C001–C011"],["14","Narratives §§8, 12, 26; original workflows 1, 2, 3, 5","Citation/support annotations only; no workflow or deadline recalculation","Replacements in §§4–5"],["15","Final self-check and raw provenance","Separate historical reads, fresh limited checks, coordinator failures, and unresolved holds","§§3, 5–6 and final audit"]]},{"headers":["#","Correction issue","Status","Claims/evidence","Exact limit or next check"],"index":8,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["#","Correction issue","Status","Claims/evidence","Exact limit or next check"],["1","General unpublished citation prohibition","Answered from official order","C001; S001 §1","Current integrated body held"],["2","Claim/issue preclusion and law-of-case exceptions","Answered","C001; S001 §1","No actual exception facts"],["3","July 1, 2009 cutoff","Answered","C002; S001 §2; S002","Issuance date matters"],["4","Authored panel or §752.31(2) single-judge requirement","Answered","C002","Status must be verified"],["5","Per curiam/memorandum/summary/other-order exclusions","Answered","C003","Date alone insufficient"],["6","Nonbinding status","Answered","C004","No controlling precedent"],["7","Court need not discuss/distinguish","Answered","C004","Persuasive use remains discretionary"],["8","Party need not research/cite","Answered","C004","No duty manufactured"],["9","File-and-serve copy requirement","Answered","C005","No citation filing performed"],["10","Official guide citation format","Answered as guidance","C006; S002","Not an amendment"],["11","2009 order’s effective date","Answered","C006; S001","Not full 2026 amendment chain"],["12","Current integrated Rule 809.23(3) body","Unresolved","S003","One failed fetch; no loop"],["13","Benitez classification","Corrected","C007","Historical six-month text not current deadline"],["14","Zander classification","Corrected","C007","Removed from ordinary persuasive support"],["15","Gregory classification/posture","Corrected","C007","Summary-judgment notice context retained"],["16","Ryan authorship/date/nonpublication","Narrowly verified","C008; existing P17-S025","No full citator"],["17","Ripco authorship/date/nonpublication and nonholding","Narrowly verified","C009; existing P17-S023","Voidness exception not decided"],["18","Ceron attribution","Preserved with qualification","C010","No fresh body/pixels/authorship certification"],["19","Dependent P17 claims","Repaired or explicitly held","C011; §4","No reliance on barred old opinions as ordinary authority"],["20","Genuine void-small-claims exception and published anchors","Unresolved/bounds preserved","C009/C011; retained P17-S019–S021","No new service-validity or bypass conclusion"]]},{"headers":["#","Hold retained","PASS-19 effect"],"index":9,"links":[],"row_links":[[],[],[],[],[],[],[]],"rows":[["#","Hold retained","PASS-19 effect"],["D1","Complete current §§799.29, 799.14, 801.14, 801.15, and 806.07 bodies","No new statute-body certification"],["D2","Meaning of “notice of motion made,” filing/service completion, electronic cutoffs, closure adjustments","No deadline recalculation or operational ruling"],["D3","Full subsequent history and citator treatment of all retained cases","No all-case certification"],["D4","Actual service, appearance, waiver, jurisdiction, judgment validity, and private facts","No individualized conclusion"],["D5","PASS-16, PASS-18, and other unreviewed modules","No findings adopted"],["D6","Remedies, fees, publication, operations, component, state, A066/A097/A098, and parent acceptance","Remain unaccepted"]]},{"headers":["#","Scope","Limit"],"index":10,"links":[],"row_links":[[],[],[],[]],"rows":[["#","Scope","Limit"],["T1","Wisconsin courts","The citation rule concerns courts of this state. All 72 counties’ local filing, service, hearing, and electronic-copy implementation remain unexamined."],["T2","Federal courts","No federal citation or Erie rule is imported from Rule 809.23."],["T3","Tribal courts, other states, and foreign jurisdictions","No citation rule or procedural permission is determined."]]},{"headers":["Unit","Count/status"],"index":11,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Unit","Count/status"],["New PASS-19 citation-rule resource rows","3"],["Successfully read new rule/guidance bodies","2"],["Failed new integrated-rule route","1"],["Existing PASS-17 opinion sources narrowly rechecked","2 — Ryan and Ripco; original IDs retained"],["PASS-17 source/case-grid status overlays","6"],["Additional previously read supporting anchors identified","4 — not freshly reread"],["New PASS-19 atomic correction claims","11"],["PASS-17 claim replacements","12 — C006, C007, C008, C011, C012, C013, C019, C020, C021, C026, C027, C050"],["Existing PASS-17 coverage rows patched","17"],["PASS-19 correction-core rows","20"],["Old-to-new crosswalk rows","15"],["New fictional citation-routing examples","2"],["Retained deferred rows","6"],["Territorial/local rows","3"]]}],"claims":[{"claim_id":"S_WI-P19-C001","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_WI-P19-C001","A066/A097/A098 status":"Open","Actor/predicate":"Party considering an unpublished Wisconsin opinion","Corrected act or effect":"General citation bar applies, subject to the three specified preclusion/law-of-case purposes and paragraph (b)","Source/pinpoint":"S001 §1, Rule 809.23(3)(a)","Exception or hold":"No exception predicate supplied for the three old cases"},"coordinator_verification_status":"scoped_correction_checked_with_remaining_holds","id_normalization":"VisiblebareCnnnqualifiedbyactualP19atomicregistercontext;rawcellunchanged"},{"claim_id":"S_WI-P19-C002","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C002","A066/A097/A098 status":"Open","Actor/predicate":"Party using a post-cutoff authored opinion","Corrected act or effect":"July 1, 2009-or-later authored panel/single-judge opinion can qualify for persuasive citation","Source/pinpoint":"S001 §2, (3)(b)","Exception or hold":"Date alone is insufficient"},"coordinator_verification_status":"scoped_correction_checked_with_remaining_holds","id_normalization":"VisiblebareCnnnqualifiedbyactualP19atomicregistercontext;rawcellunchanged"},{"claim_id":"S_WI-P19-C003","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C003","A066/A097/A098 status":"Open","Actor/predicate":"Per curiam, memorandum, summary disposition, or other order","Corrected act or effect":"These formats do not qualify as authored opinions under paragraph (b)","Source/pinpoint":"S001 §2","Exception or hold":"Paragraph (a)’s limited purposes remain distinct"},"coordinator_verification_status":"scoped_correction_checked_with_remaining_holds","id_normalization":"VisiblebareCnnnqualifiedbyactualP19atomicregistercontext;rawcellunchanged"},{"claim_id":"S_WI-P19-C004","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C004","A066/A097/A098 status":"Open","Actor/predicate":"Court and litigant","Corrected act or effect":"Eligible unpublished opinion is nonbinding; court need not discuss it; party need not research or cite it","Source/pinpoint":"S001 §2","Exception or hold":"Persuasiveness is not precedential force"},"coordinator_verification_status":"scoped_correction_checked_with_remaining_holds","id_normalization":"VisiblebareCnnnqualifiedbyactualP19atomicregistercontext;rawcellunchanged"},{"claim_id":"S_WI-P19-C005","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C005","A066/A097/A098 status":"Open","Actor/predicate":"Party actually citing an unpublished opinion","Corrected act or effect":"File and serve a copy with the citing brief or paper","Source/pinpoint":"S001 §3, (3)(c)","Exception or hold":"No paper was prepared or filed here"},"coordinator_verification_status":"scoped_correction_checked_with_remaining_holds","id_normalization":"VisiblebareCnnnqualifiedbyactualP19atomicregistercontext;rawcellunchanged"},{"claim_id":"S_WI-P19-C006","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C006","A066/A097/A098 status":"Open","Actor/predicate":"Researcher verifying current law","Corrected act or effect":"Order effective July 1, 2009; official guide corroborates distinction; current integrated body remains unread","Source/pinpoint":"S001–S003","Exception or hold":"No complete 2026 amendment-chain certification"},"coordinator_verification_status":"scoped_correction_checked_with_remaining_holds","id_normalization":"VisiblebareCnnnqualifiedbyactualP19atomicregistercontext;rawcellunchanged"},{"claim_id":"S_WI-P19-C007","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C007","A066/A097/A098 status":"Open","Actor/predicate":"Use of Benitez, Zander, Gregory","Corrected act or effect":"Retain historical reads; withdraw ordinary persuasive-authority classification","Source/pinpoint":"C001–C003 applied to supplied P17 dates/status","Exception or hold":"Historical reasoning is not declared false"},"coordinator_verification_status":"scoped_correction_checked_with_remaining_holds","id_normalization":"VisiblebareCnnnqualifiedbyactualP19atomicregistercontext;rawcellunchanged"},{"claim_id":"S_WI-P19-C008","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C008","A066/A097/A098 status":"Open","Actor/predicate":"Use of Ryan","Corrected act or effect":"Authorship, single-judge status, date, and nonpublication were narrowly rechecked; propositions remain case-specific","Source/pinpoint":"Existing S_WI-P17-S025, ¶1/fn.1, ¶¶9–12, 16–19","Exception or hold":"No full subsequent-history review"},"coordinator_verification_status":"scoped_correction_checked_with_remaining_holds","id_normalization":"VisiblebareCnnnqualifiedbyactualP19atomicregistercontext;rawcellunchanged"},{"claim_id":"S_WI-P19-C009","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C009","A066/A097/A098 status":"Open","Actor/predicate":"Use of Ripco","Corrected act or effect":"Eligible persuasive status does not turn an assumed voidness exception into a holding","Source/pinpoint":"Existing S_WI-P17-S023, ¶¶2, 10–11, 15","Exception or hold":"Genuine void-small-claims exception remains unresolved"},"coordinator_verification_status":"scoped_correction_checked_with_remaining_holds","id_normalization":"VisiblebareCnnnqualifiedbyactualP19atomicregistercontext;rawcellunchanged"},{"claim_id":"S_WI-P19-C010","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C010","A066/A097/A098 status":"Open","Actor/predicate":"Use of Ceron","Corrected act or effect":"Prior researcher body/image claims remain separate from failed coordinator access and from PASS-19","Source/pinpoint":"Supplied review record; existing S_WI-P17-S022","Exception or hold":"No new body, pixel, authorship, or citator certification"},"coordinator_verification_status":"scoped_correction_checked_with_remaining_holds","id_normalization":"VisiblebareCnnnqualifiedbyactualP19atomicregistercontext;rawcellunchanged"},{"claim_id":"S_WI-P19-C011","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"C011","A066/A097/A098 status":"Open","Actor/predicate":"P17 claim-support audit","Corrected act or effect":"Remove barred authorities from dependent claims; retain only qualified support or an explicit hold","Source/pinpoint":"Replacement tables above","Exception or hold":"No new reopening, deadline, remedy, or merits conclusion"},"coordinator_verification_status":"scoped_correction_checked_with_remaining_holds","id_normalization":"VisiblebareCnnnqualifiedbyactualP19atomicregistercontext;rawcellunchanged"},{"claim_id":"S_WI-P17-C006","area_numbers":[66,97,98],"area_assignment_method":"explicit_correction_scope","researcher_record":{"Full PASS-17 claim ID":"S_WI-P17-C006","Corrected actor/predicate/assertion and consequence":"A reopening movant using SC-515A is asked to explain both the missed answer/appearance and why the movant could prevail. This is a form-based evidence checklist, not a new universal merits rule.","Properly qualified support":"S_WI-P17-S012, SC-515A’s two explanation fields; attributed prior read","Remaining limit":"Form not freshly reread; statutes and local implementation remain held."},"raw_table_index":2,"coordinator_verification_status":"scoped_replacement_checked_with_remaining_holds"},{"claim_id":"S_WI-P17-C007","area_numbers":[66,97,98],"area_assignment_method":"explicit_correction_scope","researcher_record":{"Full PASS-17 claim ID":"S_WI-P17-C007","Corrected actor/predicate/assertion and consequence":"A court’s reopening decision is discretionary: the decision must consider relevant facts, apply the proper legal standard, and use a rational process. Remove Zander/Gregory as ordinary persuasive support.","Properly qualified support":"S_WI-P17-S025, Ryan ¶¶9, 11–12, printed pp.4–5/zero 3–4; eligible persuasive authority","Remaining limit":"Ryan does not independently substantiate every factor originally collected under this claim."},"raw_table_index":2,"coordinator_verification_status":"scoped_replacement_checked_with_remaining_holds"},{"claim_id":"S_WI-P17-C008","area_numbers":[66,97,98],"area_assignment_method":"explicit_correction_scope","researcher_record":{"Full PASS-17 claim ID":"S_WI-P17-C008","Corrected actor/predicate/assertion and consequence":"The original promptness/within-the-outer-period proposition remains attributed to the reported Ceron read, not newly verified by this correction.","Properly qualified support":"S_WI-P17-S022, reported ¶¶23–26","Remaining limit":"Ceron body, authorship, and subsequent status remain unreplicated here. Do not substitute the barred pre-2009 cases."},"raw_table_index":2,"coordinator_verification_status":"scoped_replacement_checked_with_remaining_holds"},{"claim_id":"S_WI-P17-C011","area_numbers":[66,97,98],"area_assignment_method":"explicit_correction_scope","researcher_record":{"Full PASS-17 claim ID":"S_WI-P17-C011","Corrected actor/predicate/assertion and consequence":"For the neglect theory discussed in Ryan, excusable neglect is measured against a reasonably prudent person and is not merely carelessness or inattention.","Properly qualified support":"S_WI-P17-S025, Ryan ¶12, printed p.5/zero 4","Remaining limit":"Persuasive case-specific guidance; not a categorical rule that every missed appearance is inexcusable."},"raw_table_index":2,"coordinator_verification_status":"scoped_replacement_checked_with_remaining_holds"},{"claim_id":"S_WI-P17-C012","area_numbers":[66,97,98],"area_assignment_method":"explicit_correction_scope","researcher_record":{"Full PASS-17 claim ID":"S_WI-P17-C012","Corrected actor/predicate/assertion and consequence":"A proposed meritorious position remains relevant under the previously read SC-515A and the general §806.07(h) framework in Miller. Zander is removed as ordinary persuasive support.","Properly qualified support":"S_WI-P17-S012; S_WI-P17-S021, Miller ¶36, attributed prior reads","Remaining limit":"Miller is an ordinary-civil catchall case, not an automatic chapter 799 bypass or a fresh ruling that the same factor is mandatory in every reopening case."},"raw_table_index":2,"coordinator_verification_status":"scoped_replacement_checked_with_remaining_holds"},{"claim_id":"S_WI-P17-C013","area_numbers":[66,97,98],"area_assignment_method":"explicit_correction_scope","researcher_record":{"Full PASS-17 claim ID":"S_WI-P17-C013","Corrected actor/predicate/assertion and consequence":"In Ryan, the asserted wrong-person defense did not cure the failure to challenge the lack-of-good-cause determination on appeal.","Properly qualified support":"S_WI-P17-S025, Ryan ¶¶16–19, printed pp.5–6/zero 4–5","Remaining limit":"Preserve appellate posture and the unchallenged/reply-related reasoning; do not turn it into a universal rejection of merits evidence."},"raw_table_index":2,"coordinator_verification_status":"scoped_replacement_checked_with_remaining_holds"},{"claim_id":"S_WI-P17-C019","area_numbers":[66,97,98],"area_assignment_method":"explicit_correction_scope","researcher_record":{"Full PASS-17 claim ID":"S_WI-P17-C019","Corrected actor/predicate/assertion and consequence":"Ryan discusses §806.07 factors as guideposts to §799.29 good cause. The preserved published Mercado ordinary-default boundary remains separate.","Properly qualified support":"S_WI-P17-S025, Ryan ¶11; S_WI-P17-S019, Mercado ¶¶9–14, latter as attributed prior read","Remaining limit":"Guideposts do not make §806.07 an unrestricted alternative route. No new current statute read."},"raw_table_index":2,"coordinator_verification_status":"scoped_replacement_checked_with_remaining_holds"},{"claim_id":"S_WI-P17-C020","area_numbers":[66,97,98],"area_assignment_method":"explicit_correction_scope","researcher_record":{"Full PASS-17 claim ID":"S_WI-P17-C020","Corrected actor/predicate/assertion and consequence":"Mistake, surprise, and neglect may be considered as good-cause guideposts. Remove Zander and Gregory as ordinary persuasive authority; retain Ryan’s limited discussion.","Properly qualified support":"S_WI-P17-S025, Ryan ¶¶11–12","Remaining limit":"A claimed emergency, notice defect, or other fact still requires separate proof. Gregory’s summary-judgment notice facts do not become a generic default rule."},"raw_table_index":2,"coordinator_verification_status":"scoped_replacement_checked_with_remaining_holds"},{"claim_id":"S_WI-P17-C021","area_numbers":[66,97,98],"area_assignment_method":"explicit_correction_scope","researcher_record":{"Full PASS-17 claim ID":"S_WI-P17-C021","Corrected actor/predicate/assertion and consequence":"The specific “unexplained delay inside twelve months can justify denial” application remains the original researcher’s Ceron attribution.","Properly qualified support":"S_WI-P17-S022, reported ¶¶23–26","Remaining limit":"No fresh Ceron body or image verification; no new deadline conclusion."},"raw_table_index":2,"coordinator_verification_status":"scoped_replacement_checked_with_remaining_holds"},{"claim_id":"S_WI-P17-C026","area_numbers":[66,97,98],"area_assignment_method":"explicit_correction_scope","researcher_record":{"Full PASS-17 claim ID":"S_WI-P17-C026","Corrected actor/predicate/assertion and consequence":"The late genuine-void-service exception remains unresolved in the reviewed work. Ripco assumed that exception without deciding it and affirmed on different grounds.","Properly qualified support":"S_WI-P17-S023, Ripco ¶¶2, 10–11, 15","Remaining limit":"No blanket ruling that late motions are either always permitted or always barred; no actual service determination."},"raw_table_index":2,"coordinator_verification_status":"scoped_replacement_checked_with_remaining_holds"},{"claim_id":"S_WI-P17-C050","area_numbers":[66,97,98],"area_assignment_method":"explicit_correction_scope","researcher_record":{"Full verbatim replacement passage":"S_WI-P17-C050 — Citation status of unpublished Wisconsin opinions.\nA researcher or litigant must classify an unpublished opinion by issuance date, authorship, format, and proposed use. An unpublished opinion issued before July 1, 2009 is not generally citable as persuasive authority in Wisconsin courts. The limited claim-preclusion, issue-preclusion, and law-of-the-case exceptions must be established separately. An eligible authored opinion issued on or after July 1, 2009 may be cited for persuasive value, but is not binding; excluded opinion/order formats do not qualify. If cited, a copy must be filed and served with the citing paper. Consequently, S_WI-P17-S024, S026, and S027 are historical reads—not ordinary persuasive authorities. S023 and S025 satisfy the authorship/date/nonpublication conditions observed in the limited fresh check. S022 remains subject to its separate access and authorship-verification limits.\n\nAuthority: S_WI-P19-S001, Rule 809.23(3)(a)–(c); S_WI-P19-S002.\nCurrentness limit: Complete current integrated rule and full subsequent-history review remain held.\nRegistry status: A066/A097/A098 open; no acceptance. \nWisconsin Court System\n+1"},"raw_provenance":"Literal rendered narrative fullreplacementclaim, not invented table row","coordinator_verification_status":"scoped_replacement_checked_with_remaining_holds"},{"claim_id":"S_WI-P17-C027","area_numbers":[66,97,98],"area_assignment_method":"explicit_correction_scope","researcher_record":{"Full verbatim replacement passage":"S_WI-P17-C027 — Historical Benitez discussion, not ordinary persuasive authority.\nPASS-17 recorded that the unpublished 1998 Benitez opinion distinguished an attack on a supposedly void judgment from reopening a valid default. That historical description is retained as an attributed research read only. Because the opinion predates July 1, 2009, it is not ordinarily citable for persuasive value under Rule 809.23(3). No claim-preclusion, issue-preclusion, or law-of-the-case predicate is supplied here. Its then-applicable six-month statutory discussion is historical and is not a current deadline. The opinion is therefore removed as ordinary persuasive support for a present small-claims voidness exception. That exception remains unresolved in the reviewed work; Ripco assumed it without deciding it.\n\nSources: Historical S_WI-P17-S024; citation rule S_WI-P19-S001; limited fresh Ripco check under existing S_WI-P17-S023.\nEffect: Withdraw the legal-support status, not the historical source record or its historical outcome.\nRegistry status: A066/A097/A098 open; no actual judgment is declared void. \nWisconsin Court System\n+1"},"raw_provenance":"Literal rendered narrative fullreplacementclaim, not invented table row","coordinator_verification_status":"scoped_replacement_checked_with_remaining_holds"}],"sources":[{"source_id":"S_WI-P17-S025","urls":["https://wicourts.gov/ca/opinion/DisplayDocument.pdf?content=pdf&seqNo=240493"],"researcher_record":{"Existing source ID":"S_WI-P17-S025","Official document and exact URL":"Wisconsin Court of Appeals, Ryan v. Friday, No. 2018AP1354, May 14, 2019. https://wicourts.gov/ca/opinion/DisplayDocument.pdf?content=pdf&seqNo=240493 — ¶1 and footnote 1; ¶¶9–12, 16–19; first page unnumbered/zero 0; printed pp.4–6/zero 3–5","Corrected citation status and substantive limit":"Eligible authored post-2009 unpublished opinion; persuasive, not binding. The opinion identifies Dugan, J., acting under §752.31(2)(a), and states it will not be published. Retain only the actual discretion, excusable-neglect, and appellate-posture propositions.","Access attribution":"Limited fresh PASS-19 check. Text and images at zero indexes 0, 3, 4, 5 inspected. No subsequent-history or complete-citator certification."},"coordinator_verification_status":"checked_against_precisely_dated_P17_coordinator_record_with_retained_limits","coordinator_check_record":"[internal evidence reference]","coordinator_check_at":"2026-10-27T05:55:32.798912+00:00","usage_scope":"3newregisteredcitationresources(2bodies1failedroute)+2freshnarrowrechecksunderexistingIDs;4nonfreshstatusoverlaysnotnewusage"},{"source_id":"S_WI-P17-S023","urls":["https://www.wicourts.gov/ca/opinion/DisplayDocument.pdf?content=pdf&seqNo=162063"],"researcher_record":{"Existing source ID":"S_WI-P17-S023","Official document and exact URL":"Wisconsin Court of Appeals, Ripco Credit Union v. Kennedy, No. 2015AP1280, February 23, 2016. https://www.wicourts.gov/ca/opinion/DisplayDocument.pdf?content=pdf&seqNo=162063 — ¶1/footnote 1; ¶¶2, 9–11, 15; first page unnumbered/zero 0; printed p.5/zero 4; printed p.9/zero 8","Corrected citation status and substantive limit":"Eligible authored post-2009 unpublished opinion; persuasive, not binding. Hruz, J., decided it under §752.31(2). It assumed without deciding the late void-judgment exception and resolved that appeal on its service facts. It did not establish the exception.","Access attribution":"Limited fresh PASS-19 check. Relevant text and images at zero 0, 4, 8 inspected. No actual party’s service is adjudicated here."},"coordinator_verification_status":"checked_against_precisely_dated_P17_coordinator_record_with_retained_limits","coordinator_check_record":"[internal evidence reference]","coordinator_check_at":"2026-10-27T05:55:32.798912+00:00","usage_scope":"3newregisteredcitationresources(2bodies1failedroute)+2freshnarrowrechecksunderexistingIDs;4nonfreshstatusoverlaysnotnewusage"},{"source_id":"S_WI-P19-S001","urls":["https://www.wicourts.gov/sc/scord/DisplayDocument.html?content=html&seqNo=35116"],"researcher_record":{"Source ID":"S_WI-P19-S001","Issuer/title and full literal URL":"Wisconsin Supreme Court, 2009 WI 2, Rule Order No. 08-02. https://www.wicourts.gov/sc/scord/DisplayDocument.html?content=html&seqNo=35116","Pinpoint, version, commencement":"§§1–3: Rule 809.23(3)(a)–(c); entered January 6, 2009; effective July 1, 2009. HTML; printed-page/PDF index not applicable","Fresh access and read limit":"Fresh full relevant order body read, October 26 Pacific/October 27 UTC. Posted order contains an editing notice. Not a full 2026 amendment-chain certification. \nWisconsin Court System"},"coordinator_verification_status":"checked_against_precisely_dated_P17_coordinator_record_with_retained_limits","coordinator_check_record":"[internal evidence reference]","coordinator_check_at":"2026-10-27T05:55:32.798912+00:00","usage_scope":"3newregisteredcitationresources(2bodies1failedroute)+2freshnarrowrechecksunderexistingIDs;4nonfreshstatusoverlaysnotnewusage"},{"source_id":"S_WI-P19-S002","urls":["https://www.wicourts.gov/opinions/appeals2.htm"],"researcher_record":{"Source ID":"S_WI-P19-S002","Issuer/title and full literal URL":"Wisconsin Court System, Court of Appeals opinions guide. https://www.wicourts.gov/opinions/appeals2.htm","Pinpoint, version, commencement":"“Precedential value of opinions”; “Citation of unpublished opinions.” No authoritative legal-effective date supplied by the webpage","Fresh access and read limit":"Fresh relevant guidance body read, same access dates. Current accessibility is not proof that every page detail was updated in 2026. \nWisconsin Court System"},"coordinator_verification_status":"checked_against_precisely_dated_P17_coordinator_record_with_retained_limits","coordinator_check_record":"[internal evidence reference]","coordinator_check_at":"2026-10-27T05:55:32.798912+00:00","usage_scope":"3newregisteredcitationresources(2bodies1failedroute)+2freshnarrowrechecksunderexistingIDs;4nonfreshstatusoverlaysnotnewusage"},{"source_id":"S_WI-P19-S003","urls":["https://docs.legis.wisconsin.gov/statutes/statutes/809/iii/23/3"],"researcher_record":{"Source ID":"S_WI-P19-S003","Issuer/title and full literal URL":"Wisconsin Legislature, Rule 809.23(3), integrated statute endpoint. https://docs.legis.wisconsin.gov/statutes/statutes/809/iii/23/3","Pinpoint, version, commencement":"Intended current paragraphs (a)–(c)","Fresh access and read limit":"One fresh failed fetch: timeout, same access dates. No integrated body read; no repeated retry or workaround. (Invalid URL)"},"coordinator_verification_status":"checked_against_precisely_dated_P17_coordinator_record_with_retained_limits","coordinator_check_record":"[internal evidence reference]","coordinator_check_at":"2026-10-27T05:55:32.798912+00:00","usage_scope":"3newregisteredcitationresources(2bodies1failedroute)+2freshnarrowrechecksunderexistingIDs;4nonfreshstatusoverlaysnotnewusage"}],"coverage":[{"topic":"1 General unpublished citation prohibition","researcher_record":{"#":"1","Correction issue":"General unpublished citation prohibition","Status":"Answered from official order","Claims/evidence":"C001; S001 §1","Exact limit or next check":"Current integrated body held"},"raw_table_index":8,"coordinator_acceptance":"scoped_repair_or_retained_hold_not_parent_acceptance"},{"topic":"2 Claim/issue preclusion and law-of-case exceptions","researcher_record":{"#":"2","Correction issue":"Claim/issue preclusion and law-of-case exceptions","Status":"Answered","Claims/evidence":"C001; S001 §1","Exact limit or next check":"No actual exception facts"},"raw_table_index":8,"coordinator_acceptance":"scoped_repair_or_retained_hold_not_parent_acceptance"},{"topic":"3 July 1, 2009 cutoff","researcher_record":{"#":"3","Correction issue":"July 1, 2009 cutoff","Status":"Answered","Claims/evidence":"C002; S001 §2; S002","Exact limit or next check":"Issuance date matters"},"raw_table_index":8,"coordinator_acceptance":"scoped_repair_or_retained_hold_not_parent_acceptance"},{"topic":"4 Authored panel or §752.31(2) single-judge requirement","researcher_record":{"#":"4","Correction issue":"Authored panel or §752.31(2) single-judge requirement","Status":"Answered","Claims/evidence":"C002","Exact limit or next check":"Status must be verified"},"raw_table_index":8,"coordinator_acceptance":"scoped_repair_or_retained_hold_not_parent_acceptance"},{"topic":"5 Per curiam/memorandum/summary/other-order exclusions","researcher_record":{"#":"5","Correction issue":"Per curiam/memorandum/summary/other-order exclusions","Status":"Answered","Claims/evidence":"C003","Exact limit or next check":"Date alone insufficient"},"raw_table_index":8,"coordinator_acceptance":"scoped_repair_or_retained_hold_not_parent_acceptance"},{"topic":"6 Nonbinding status","researcher_record":{"#":"6","Correction issue":"Nonbinding status","Status":"Answered","Claims/evidence":"C004","Exact limit or next check":"No controlling precedent"},"raw_table_index":8,"coordinator_acceptance":"scoped_repair_or_retained_hold_not_parent_acceptance"},{"topic":"7 Court need not discuss/distinguish","researcher_record":{"#":"7","Correction issue":"Court need not discuss/distinguish","Status":"Answered","Claims/evidence":"C004","Exact limit or next check":"Persuasive use remains discretionary"},"raw_table_index":8,"coordinator_acceptance":"scoped_repair_or_retained_hold_not_parent_acceptance"},{"topic":"8 Party need not research/cite","researcher_record":{"#":"8","Correction issue":"Party need not research/cite","Status":"Answered","Claims/evidence":"C004","Exact limit or next check":"No duty manufactured"},"raw_table_index":8,"coordinator_acceptance":"scoped_repair_or_retained_hold_not_parent_acceptance"},{"topic":"9 File-and-serve copy requirement","researcher_record":{"#":"9","Correction issue":"File-and-serve copy requirement","Status":"Answered","Claims/evidence":"C005","Exact limit or next check":"No citation filing performed"},"raw_table_index":8,"coordinator_acceptance":"scoped_repair_or_retained_hold_not_parent_acceptance"},{"topic":"10 Official guide citation format","researcher_record":{"#":"10","Correction issue":"Official guide citation format","Status":"Answered as guidance","Claims/evidence":"C006; S002","Exact limit or next check":"Not an amendment"},"raw_table_index":8,"coordinator_acceptance":"scoped_repair_or_retained_hold_not_parent_acceptance"},{"topic":"11 2009 order’s effective date","researcher_record":{"#":"11","Correction issue":"2009 order’s effective date","Status":"Answered","Claims/evidence":"C006; S001","Exact limit or next check":"Not full 2026 amendment chain"},"raw_table_index":8,"coordinator_acceptance":"scoped_repair_or_retained_hold_not_parent_acceptance"},{"topic":"12 Current integrated Rule 809.23(3) body","researcher_record":{"#":"12","Correction issue":"Current integrated Rule 809.23(3) body","Status":"Unresolved","Claims/evidence":"S003","Exact limit or next check":"One failed fetch; no loop"},"raw_table_index":8,"coordinator_acceptance":"scoped_repair_or_retained_hold_not_parent_acceptance"},{"topic":"13 Benitez classification","researcher_record":{"#":"13","Correction issue":"Benitez classification","Status":"Corrected","Claims/evidence":"C007","Exact limit or next check":"Historical six-month text not current deadline"},"raw_table_index":8,"coordinator_acceptance":"scoped_repair_or_retained_hold_not_parent_acceptance"},{"topic":"14 Zander classification","researcher_record":{"#":"14","Correction issue":"Zander classification","Status":"Corrected","Claims/evidence":"C007","Exact limit or next check":"Removed from ordinary persuasive support"},"raw_table_index":8,"coordinator_acceptance":"scoped_repair_or_retained_hold_not_parent_acceptance"},{"topic":"15 Gregory classification/posture","researcher_record":{"#":"15","Correction issue":"Gregory classification/posture","Status":"Corrected","Claims/evidence":"C007","Exact limit or next check":"Summary-judgment notice context retained"},"raw_table_index":8,"coordinator_acceptance":"scoped_repair_or_retained_hold_not_parent_acceptance"},{"topic":"16 Ryan authorship/date/nonpublication","researcher_record":{"#":"16","Correction issue":"Ryan authorship/date/nonpublication","Status":"Narrowly verified","Claims/evidence":"C008; existing P17-S025","Exact limit or next check":"No full citator"},"raw_table_index":8,"coordinator_acceptance":"scoped_repair_or_retained_hold_not_parent_acceptance"},{"topic":"17 Ripco authorship/date/nonpublication and nonholding","researcher_record":{"#":"17","Correction issue":"Ripco authorship/date/nonpublication and nonholding","Status":"Narrowly verified","Claims/evidence":"C009; existing P17-S023","Exact limit or next check":"Voidness exception not decided"},"raw_table_index":8,"coordinator_acceptance":"scoped_repair_or_retained_hold_not_parent_acceptance"},{"topic":"18 Ceron attribution","researcher_record":{"#":"18","Correction issue":"Ceron attribution","Status":"Preserved with qualification","Claims/evidence":"C010","Exact limit or next check":"No fresh body/pixels/authorship certification"},"raw_table_index":8,"coordinator_acceptance":"scoped_repair_or_retained_hold_not_parent_acceptance"},{"topic":"19 Dependent P17 claims","researcher_record":{"#":"19","Correction issue":"Dependent P17 claims","Status":"Repaired or explicitly held","Claims/evidence":"C011; §4","Exact limit or next check":"No reliance on barred old opinions as ordinary authority"},"raw_table_index":8,"coordinator_acceptance":"scoped_repair_or_retained_hold_not_parent_acceptance"},{"topic":"20 Genuine void-small-claims exception and published anchors","researcher_record":{"#":"20","Correction issue":"Genuine void-small-claims exception and published anchors","Status":"Unresolved/bounds preserved","Claims/evidence":"C009/C011; retained P17-S019–S021","Exact limit or next check":"No new service-validity or bypass conclusion"},"raw_table_index":8,"coordinator_acceptance":"scoped_repair_or_retained_hold_not_parent_acceptance"},{"topic":"D1 Complete current §§799.29, 799.14, 801.14, 801.15, and 806.07 bodies","researcher_record":{"#":"D1","Hold retained":"Complete current §§799.29, 799.14, 801.14, 801.15, and 806.07 bodies","PASS-19 effect":"No new statute-body certification"},"raw_table_index":9,"coordinator_acceptance":"scoped_repair_or_retained_hold_not_parent_acceptance"},{"topic":"D2 Meaning of “notice of motion made,” filing/service completion, electronic cutoffs, closure adjustments","researcher_record":{"#":"D2","Hold retained":"Meaning of “notice of motion made,” filing/service completion, electronic cutoffs, closure adjustments","PASS-19 effect":"No deadline recalculation or operational ruling"},"raw_table_index":9,"coordinator_acceptance":"scoped_repair_or_retained_hold_not_parent_acceptance"},{"topic":"D3 Full subsequent history and citator treatment of all retained cases","researcher_record":{"#":"D3","Hold retained":"Full subsequent history and citator treatment of all retained cases","PASS-19 effect":"No all-case certification"},"raw_table_index":9,"coordinator_acceptance":"scoped_repair_or_retained_hold_not_parent_acceptance"},{"topic":"D4 Actual service, appearance, waiver, jurisdiction, judgment validity, and private facts","researcher_record":{"#":"D4","Hold retained":"Actual service, appearance, waiver, jurisdiction, judgment validity, and private facts","PASS-19 effect":"No individualized conclusion"},"raw_table_index":9,"coordinator_acceptance":"scoped_repair_or_retained_hold_not_parent_acceptance"},{"topic":"D5 PASS-16, PASS-18, and other unreviewed modules","researcher_record":{"#":"D5","Hold retained":"PASS-16, PASS-18, and other unreviewed modules","PASS-19 effect":"No findings adopted"},"raw_table_index":9,"coordinator_acceptance":"scoped_repair_or_retained_hold_not_parent_acceptance"},{"topic":"D6 Remedies, fees, publication, operations, component, state, A066/A097/A098, and parent acceptance","researcher_record":{"#":"D6","Hold retained":"Remedies, fees, publication, operations, component, state, A066/A097/A098, and parent acceptance","PASS-19 effect":"Remain unaccepted"},"raw_table_index":9,"coordinator_acceptance":"scoped_repair_or_retained_hold_not_parent_acceptance"},{"topic":"T1 Wisconsin courts","researcher_record":{"#":"T1","Scope":"Wisconsin courts","Limit":"The citation rule concerns courts of this state. All 72 counties’ local filing, service, hearing, and electronic-copy implementation remain unexamined."},"raw_table_index":10,"coordinator_acceptance":"scoped_repair_or_retained_hold_not_parent_acceptance"},{"topic":"T2 Federal courts","researcher_record":{"#":"T2","Scope":"Federal courts","Limit":"No federal citation or Erie rule is imported from Rule 809.23."},"raw_table_index":10,"coordinator_acceptance":"scoped_repair_or_retained_hold_not_parent_acceptance"},{"topic":"T3 Tribal courts, other states, and foreign jurisdictions","researcher_record":{"#":"T3","Scope":"Tribal courts, other states, and foreign jurisdictions","Limit":"No citation rule or procedural permission is determined."},"raw_table_index":10,"coordinator_acceptance":"scoped_repair_or_retained_hold_not_parent_acceptance"}],"annotations":{},"corrections":[],"resolved_corrections":[],"review_history":[]}