{"meta":{"key":"s_wi--pass-22","task":"S_WI","title":"Narrow supplement: the 1979 Milwaukee Police confirmation-response holding","parent_title":"Wisconsin debt and debt relief law","edition":"pass-22","path":"/research/s_wi--pass-22/","kind":"split_pass","category":"state","role":"state","area_numbers":[66],"groups":["collections"],"date":"2026-10-27","tables":13,"claims":9,"sources":2,"review_status":"C027original1979primary_opinion_text_checked;official_facsimile_currentlaw_laterhistory_application_holds_retained","review_complete":true,"sha256":"3e1d168410d5d1435cda737098828694e7d6c340d5992bd42ab68702e9ba9799","headings":["Narrow supplement: the 1979 Milwaukee Police confirmation-response holding","2.1 Majority holding at pages 164–65","2.2 Actual procedural context","2.3 Statutory version and terminology","2.4 Majority, merits outcome, and dissent","2.5 What the decision does not resolve","4.1 PASS-18 G1.11 and PASS-20’s source-pending paragraph","4.2 Affected existing coverage cells","4.3 Existing workflows 4 and 5","Nonfresh source overlays","Example A — Statutory objection in a pending confirmation proceeding","Example B — Late standalone fraud challenge, no confirmation application","Deferred verification and application","Territorial/local boundaries"],"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-22","facets":{"geography":["us","us-wi"],"debt_type":[],"stage":[],"subject":[]},"scope":"ReviewedP18/P20C027correct1979MilwaukeePoliceprimarybody/defensiveconfirmationexceptionONLY;C028fraudtollingseparatehold.","pending_corrections":0},"markdown":"# SettleADebt S_WI PASS-22\n\n## Narrow supplement: the 1979 Milwaukee Police confirmation-response holding\n\n**Fresh access date:** October 26, 2026, America/Los_Angeles; October 27, 2026 UTC. Exact individual source-opening times are unknown.\n\n**Disposition:** The intended **1979 published opinion body was obtained and read**, including reporter pages **164–65** and the necessary surrounding majority and dissenting discussion. It directly supports the narrow defensive-confirmation exception reported in PASS-18 C027.\n\nThe source is a **full public reproduction of the judicial opinion on Justia**, not a court-hosted scan of the bound reporter. Thus, the missing-opinion-text gap is resolved at the published-opinion-body level; an official reporter facsimile, current consolidated chapter 788, and complete subsequent-history certification remain unverified.\n\nNo PASS-21 conclusion is adopted. The other PASS-18/PASS-20 corrections remain unchanged.\n\n# 1. What was obtained—and what was not\n\n| Material | PASS-22 result | Evidentiary classification |\n| --- | --- | --- |\n| **Milwaukee Police Association v. City of Milwaukee, 92 Wis. 2d 145, 285 N.W.2d 119 (1979)** | Full opinion reproduction opened; majority, material context, and separate dissent read | **Fresh published judicial opinion body on a nonofficial public host** |\n| Reporter pages **164–65** | Read through the reproduction’s explicit reporter-page markers | Textual page verification, **not pixel inspection of a reporter scan** |\n| Official court/reporter facsimile | Not obtained | Remaining format/authentication limit |\n| Public reporter-library alternate | One reconstructed reporter locator failed | Failed retrieval, not absence of the opinion |\n| Current official annotation body | Not obtained in this pass | Earlier P20 indexed annotation remains discovery only |\n| Later published majority applying this exact exception | None opened and relied upon in this pass | No later-authority or complete-citator claim |\n| Current chapter 788 HTML/PDF | Not retried | Prior access/currentness holds preserved |\n| Brown County | Not reopened or relied upon | Existing historical-only classification preserved |\n\nThe intended opinion is **92 Wis. 2d 145 / 285 N.W.2d 119**, not the different **92 Wis. 2d 175 / 285 N.W.2d 133** decision. The opened reproduction identifies the Wisconsin Supreme Court, decision date **November 6, 1979**, and the correct reporter citations. **S_WI-P22-C001.** [Justia Law](https://law.justia.com/cases/wisconsin/supreme-court/1979/77-115-7.html)\n\n**Primary opinion URL for the substantive findings below:**\nhttps://law.justia.com/cases/wisconsin/supreme-court/1979/77-115-7.html\n\n# 2. The exact narrow holding\n\n## 2.1 Majority holding at pages 164–65\n\nThe majority held that the three-month restriction in former **Wis. Stat. §298.13** did not prevent an adverse party from responding to the prevailing party’s confirmation application with statutory grounds to vacate, modify, or correct under former **§§298.10 and 298.11**.\n\nThat was a **response to a timely court-confirmation application**, not an unrestricted right to initiate an affirmative challenge whenever desired. **S_WI-P22-C003–C004.**\n\n**Pinpoint:** Majority’s final substantive paragraph, reporter **p.165**, following its analysis at **pp.162–65**, under the heading **“APPLICATION OF SEC. 298.09, STATS., TO A MOTION TO CONFIRM AN AWARD.”** The bracketed “[12]” in the reproduction is not treated as a modern numbered judicial paragraph. [law.justia.com](https://law.justia.com/cases/wisconsin/supreme-court/1979/77-115-7.html)\n\n## 2.2 Actual procedural context\n\nThe reported sequence was:\n\n| Event | Date stated in the opinion |\n| --- | --- |\n| Arbitration award | October 20, 1976 |\n| Prevailing association’s court motion to confirm | March 29, 1977 |\n| City’s responsive motion to dismiss | April 7, 1977 |\n| Circuit court confirmation order | June 6, 1977 |\n| Judgment entered | July 21, 1977 |\n\nThe City had not moved within the three-month period. The Supreme Court treated its responsive dismissal motion as tantamount to a motion to vacate because it asserted that the arbitrator exceeded his authority. **S_WI-P22-C002–C004.**\n\n**Pinpoints:** Reporter **pp.149–50, 162–63**. [Justia Law+1](https://law.justia.com/cases/wisconsin/supreme-court/1979/77-115-7.html)\n\nThe nine-day interval between the confirmation application and response is a **case fact**, not a response deadline established by the decision. No present response, service, briefing, or hearing period is calculated here.\n\n## 2.3 Statutory version and terminology\n\nThe opinion applied and quoted **former chapter 298**, specifically §§298.09, 298.10, 298.11, and 298.13. It also stated that the parties’ collective-bargaining agreement incorporated §§298.08–298.15.\n\nThe relevant quoted statutory periods were:\n\n- confirmation within **one year after the award was made**; and\n- service of notice seeking vacatur, modification, or correction within **three months after the award was filed or delivered**.\n\nThe issue statement elsewhere used “ninety days,” but the operative statutory quotation used **three months**. This supplement does not convert those units into one another. **S_WI-P22-C002.**\n\n**Pinpoints:** Reporter **pp.150, 160–62**. The particular biennial statutory-edition year is not expressly identified in the material text read, so none is invented. [Justia Law+1](https://law.justia.com/cases/wisconsin/supreme-court/1979/77-115-7.html)\n\n## 2.4 Majority, merits outcome, and dissent\n\nThe timing conclusion was a **majority holding**, not merely an annotation or a later court’s summary. Separately, the majority concluded that the grievance was arbitrable but the arbitrator exceeded the contractual authority in granting the remedy. The Court reversed the confirming judgment. **S_WI-P22-C005.**\n\n**Pinpoints:** Reporter **pp.152–53, 158–60, 165**. [Justia Law+1](https://law.justia.com/cases/wisconsin/supreme-court/1979/77-115-7.html)\n\nJustice Abrahamson dissented, joined by Justice Day. The dissent would have enforced the three-month restriction against the late response and criticized the majority’s interpretation. Its discussion is not the Court’s holding. **S_WI-P22-C006.**\n\n**Pinpoints:** Dissent begins at **p.165**; relevant disagreement at **pp.165–68**; joinder statement at **p.175**. The presence of page 175 within this dissent does not change the identity of the opinion starting at page 145. [Justia Law](https://law.justia.com/cases/wisconsin/supreme-court/1979/77-115-7.html)\n\n## 2.5 What the decision does not resolve\n\nThis decision supplies no generalized **fraud-discovery tolling rule**. Its actual challenge concerned excess of arbitral authority, and the timing holding depended on a confirmation-response posture. It does not establish:\n\n- a new three-month period beginning when fraud is discovered;\n- an unlimited standalone right to vacate;\n- permission to ignore a pending confirmation proceeding;\n- reopening of an already entered confirmation judgment without a separate proper route;\n- waiver of filing, service, or court-scheduling requirements; or\n- the governing rule for every FAA, foreign-award, or differently regulated proceeding.\n\n**S_WI-P22-C004, C007–C008.** These are limits on what this source establishes, not findings that every other possible remedy is unavailable. [Justia Law+1](https://law.justia.com/cases/wisconsin/supreme-court/1979/77-115-7.html)\n\n# 3. Full replacement for the original PASS-18 C027 cell\n\nThe supplied original record identifies the cell as S_WI-C027; its pass-qualified identity in this correction is **S_WI-P18-C027**.\n\n| Field | Replacement |\n| --- | --- |\n| **Claim ID** | **S_WI-P18-C027** |\n| **Area** | A066; component and parent status remain open |\n| **Actor / predicate** | Adverse arbitration party responding to the prevailing party’s **timely court application to confirm**, rather than independently initiating an otherwise late challenge |\n| **Precise assertion** | In *Milwaukee Police Association v. City of Milwaukee*, 92 Wis. 2d 145, 164–65, 285 N.W.2d 119 (1979), the Wisconsin Supreme Court held under former §§298.09–298.13 that expiration of the three-month challenge period did not bar the adverse party’s responsive request to vacate, modify, or correct on statutory grounds. |\n| **Required act / consequence** | Raise a legally sufficient statutory objection in the confirmation proceeding through the proper response. The case does not supply a new universal response deadline, excuse defective service, or establish that the objection succeeds on its merits. |\n| **Primary pinpoint** | **S_WI-P22-S001**, majority pp.162–65, especially the final holding at p.165; procedural context pp.149–50 |\n| **Source status** | **Published opinion body freshly read in a full public reproduction.** Previous missing-body status is resolved at that level. |\n| **Host / verification limit** | Justia is not the official judiciary or bound reporter. No official reporter-page image was inspected. |\n| **Currentness / application limit** | The opinion applies former chapter 298. Existing chapter 788 current-body, governing-law, later-treatment, local-service, actual-award, and forum holds remain. No full modern FAA or other-jurisdiction conclusion is added. |\n| **Exceptions / scope** | Narrow confirmation-response posture. No fraud-discovery tolling holding and no unrestricted affirmative late-vacatur right. |\n| **Review status** | Research supplement only; not independent review or coordinator acceptance |\n\n**Direct source:**\nhttps://law.justia.com/cases/wisconsin/supreme-court/1979/77-115-7.html, majority **pp.162–65**. [law.justia.com](https://law.justia.com/cases/wisconsin/supreme-court/1979/77-115-7.html)\n\n# 4. Only necessary narrative and coverage replacements\n\n## 4.1 PASS-18 G1.11 and PASS-20’s source-pending paragraph\n\nReplace the source-pending qualification with:\n\nThe missing 1979 published-opinion text has now been read in PASS-22. It directly supports corrected **S_WI-P18-C027’s narrow confirmation-response proposition**. The primary support is the 1979 majority itself, not Brown County or an indexed annotation. The official-hosted facsimile, complete current chapter 788, and full subsequent-treatment checks remain separate holds.\n\nNo new blanket statement that a late challenge is timely should be added.\n\n## 4.2 Affected existing coverage cells\n\n| Original location | Replacement status | Evidence and remaining limit |\n| --- | --- | --- |\n| **P18 core row 41 — Confirmation-response exception** | **Supported by freshly read published-opinion body, within stated historical/currentness limits** | Corrected C027; P22-S001, pp.162–65 |\n| **P18 core row 42 — Unlimited tolling** | **Unchanged: no unlimited-tolling rule established** | C028 remains historical-only; the new opinion is not a fraud-tolling decision |\n| **P18 core row 82 — Fraud procurement** | **Unchanged** | No fresh §788.10 body or fraud-proof analysis in this pass |\n| **P18 core row 83 — Fraud discovery timing** | **Unchanged: unresolved as a general tolling question** | Corrected C053’s separation of procurement and timing remains |\n| **P20 core row 6 — Exact Milwaukee Police target** | **Exact target now opened** | Correct citations and opinion identity verified from P22-S001 |\n| **P20 core row 7 — C027 support pending** | **Opinion-text gap resolved by this supplement** | P20’s earlier “pending” observation remains accurate as historical provenance; it is not rewritten |\n\n## 4.3 Existing workflows 4 and 5\n\n| PASS-18 workflow | Narrow annotation only |\n| --- | --- |\n| **Workflow 4 — late standalone notice** | Its alternative involving a later timely confirmation request may now cite corrected C027 and P22-S001. That does not cure the standalone branch or establish a response deadline. |\n| **Workflow 5 — fraud discovered after award** | A genuine confirmation-response posture may invoke corrected C027, but discovery of fraud alone does not trigger this exception. Fraud tolling remains unresolved. |\n\nNo dates, arithmetic, or other facts in the original fifteen workflows were recalculated.\n\n# 5. Source register — S_WI-P22-S001 onward\n\nAll fresh accesses occurred **October 26, 2026 Pacific / October 27, 2026 UTC**. Exact individual opening times are unknown.\n\n| Source ID | Issuer/title/full literal URL | Edition, status, pinpoint | Actual reading and limits |\n| --- | --- | --- | --- |\n| **S_WI-P22-S001** | **Wisconsin Supreme Court opinion, publicly reproduced by Justia:** *Milwaukee Police Association v. City of Milwaukee*, 92 Wis. 2d 145, 285 N.W.2d 119 (1979). https://law.justia.com/cases/wisconsin/supreme-court/1979/77-115-7.html | Decided November 6, 1979. Majority by Connor T. Hansen, J.; separate Abrahamson dissent joined by Day. Material reporter pages **149–50, 160–65**; dissent **165–75**. Former §§298.09–.13 quoted. | **Fresh opinion body read**, including the material majority, adjacent context, dissent, and relevant footnotes. This is judicial text, not the publisher’s summary. Host is nonofficial. HTML reporter markers read; **PDF index not applicable; no reporter pixels inspected**. No current statutory commencement or full citator certification. |\n| **S_WI-P22-S002** | **Attempted public case-reporter library locator.** https://cite.case.law/wis-2d/92/145/ | Locator reconstructed from the exact reporter citation; no returned opinion title, edition, or pages could be validated | **One failed fetch:** inaccessible through the tool. No retry or workaround. This failure neither disproves the opinion nor authenticates a facsimile. The successful public reproduction in S001 supplies the text actually used. |\n\n**New resource rows: 2 — one successful opinion-body resource and one failed reporter-library route.** [Justia Law](https://law.justia.com/cases/wisconsin/supreme-court/1979/77-115-7.html)\n\n## Nonfresh source overlays\n\nThese are provenance entries, not new resources or fresh reads.\n\n| Earlier source | Existing status preserved | PASS-22 treatment |\n| --- | --- | --- |\n| **S_WI-P20-S003** — https://docs.legis.wisconsin.gov/document/statutes/788.11%281%29%28c%29 | Official indexed annotation lead only | Not reopened or upgraded. It no longer carries the burden of supplying the original holding. |\n| **S_WI-P18-S024** — https://www.wicourts.gov/ca/opinion/DisplayDocument.html?content=html&seqNo=19110 | Brown County: historical-only, pre-2009 unpublished per curiam | Not reopened or relied on as persuasive authority. C028’s limitation remains. |\n| **S_WI-P18-S005** — https://law.justia.com/codes/wisconsin/chapter-788/section-788-10/ | Prior nonofficial statutory read-aid with current-body hold | Not reread. C053’s procurement support and its separate timing hold are unchanged. |\n\nThe supplied P18/P20 coordinator review timestamps remain review metadata, not source-opening clocks.\n\n# 6. New atomic claim register\n\nEvery new claim remains **A066/A097/A098 and parent status open**.\n\n| Claim ID | Actor / predicate | Atomic assertion or consequence | Source / pinpoint | Exception and remaining hold |\n| --- | --- | --- | --- | --- |\n| **S_WI-P22-C001** | Researcher identifying precedent | The exact 92 Wis. 2d 145 / 285 N.W.2d 119 opinion body was opened; the distinct page-175 case was not substituted | S001 heading and reporter identifiers | Nonofficial reproduction host; no official facsimile |\n| **C002** | Court applying historical arbitration statutes | The case used former chapter 298 and involved a timely confirmation application followed by a responsive challenge | S001 pp.149–50, 160–63 | Exact biennial edition not stated; current consolidation not verified |\n| **C003** | Adverse party responding to winner’s confirmation request | Three-month expiration did not itself bar statutory vacatur/modification/correction grounds in that response posture | S001 pp.164–65, final majority holding | Proper response and statutory ground still required |\n| **C004** | Party considering affirmative versus defensive relief | The holding does not create a general independent late-motion right or a new response deadline | S001 pp.162–65 | Actual service, scheduling, finality, and posture remain unknown |\n| **C005** | Reviewing court | The majority reversed confirmation after finding excess of arbitral authority | S001 pp.158–60, 165 | Labor-contract merits are not transferred to a consumer award |\n| **C006** | Reader distinguishing writings | Abrahamson’s strict-deadline approach, joined by Day, is dissent—not the holding | S001 pp.165–75 | Disagreement does not itself establish later reversal |\n| **C007** | Fraud-based challenger | This opinion does not decide discovery-of-fraud tolling | S001’s actual issues and timing analysis, pp.150, 160–65 | C028/C053 timing limitations remain |\n| **C008** | Registry/source-status reviewer | The original-opinion-text gap is resolved; official-facsimile, current-law, governing-route, and later-treatment holds remain | S001–S002; supplied P18/P20 record | No current all-source or actual-case certification |\n\n**New atomic claims: 8.**\n\n# 7. Two fictional posture examples\n\n## Example A — Statutory objection in a pending confirmation proceeding\n\n**Stipulated facts:** A Wisconsin-governed arbitration winner timely asks a court to confirm. More than three months have elapsed since the relevant award event. The opponent promptly responds, alleging a statutory excess-of-powers ground.\n\n**Route supported by the source:** Corrected **S_WI-P18-C027 / P22-C003** allows consideration of that statutory objection notwithstanding expiration of the ordinary three-month challenge period. This addresses the timing obstacle—not whether the arbitrator actually exceeded authority. [law.justia.com](https://law.justia.com/cases/wisconsin/supreme-court/1979/77-115-7.html)\n\n**Adverse branch:** The result cannot simply be transferred to a differently governed award, a different forum, a response made contrary to the applicable court schedule, or a proceeding in which confirmation judgment has already become final.\n\n**Missing facts:** Agreement, governing law, award, actual confirmation application, delivery evidence, response/service record, and alleged excess of authority. No actual deadline or outcome is determined.\n\n## Example B — Late standalone fraud challenge, no confirmation application\n\n**Stipulated facts:** The award loser discovers alleged fraud after the ordinary challenge period and independently asks a court to vacate. The winner has not applied for judicial confirmation.\n\n**Result of this source check:** The newly read opinion does **not** supply the requested timing extension. Its response-posture predicate is missing, and it did not decide fraud-discovery tolling. **P22-C004/C007.** [law.justia.com](https://law.justia.com/cases/wisconsin/supreme-court/1979/77-115-7.html)\n\n**Adverse branch:** A separate, actually established tolling or other remedy might matter, but none is certified by this pass. If a timely confirmation request later creates the relevant posture, that would require a separate procedural analysis—not retroactive permission for every earlier late motion.\n\n**Missing facts:** Actual fraud, diligence, governing statute, delivery event, pending court proceedings, and applicable service rules.\n\n**New fictional workflows: 2.**\n\n# 8. Exact old-to-new crosswalk\n\n| # | P18/P20 location | PASS-22 change | Status |\n| --- | --- | --- | --- |\n| 1 | **S_WI-P18-C027**, originally supported by “S024 ¶3; Milwaukee Police rule” | Replace with the complete cell in §3, supported directly by P22-S001 | Opinion-body support obtained |\n| 2 | **P18 G1.11** confirmation-response paragraph | Replace source-pending sentence with direct majority support and retained limits | Narrow narrative replacement |\n| 3 | **P18 core row 41** | Update from pending to supported within source/currentness bounds | Existing row only |\n| 4 | **P18 workflow 4 alternative** | Add direct support for genuine confirmation-response posture | No date/model rerun |\n| 5 | **P18 workflow 5 alternative** | Separate available response posture from unresolved fraud tolling | No new extension |\n| 6 | **P18 C028/core row 42** | Preserve historical-only Brown County and no generalized tolling conclusion | Unchanged |\n| 7 | **P18 C053/core rows 82–83** | Preserve procurement/timing separation | Unchanged |\n| 8 | **P18 S024** | Remove no history; do not restore persuasive status | Unchanged source classification |\n| 9 | **P20 §2.2 and C027 pending cell** | Append this successful opinion-body retrieval; preserve the earlier pending observation as accurate when made | New provenance layer |\n| 10 | **P20 core rows 6–7** | Exact target obtained; original-text gap closed at public-reproduction level | Existing rows supplemented |\n| 11 | **P20 retained D2 source gap** | Narrow remaining gap to official facsimile/current-law/later-treatment verification | Not complete acceptance |\n| 12 | P20 Minerals, Jones, SC-6000, Sewart repairs; P18 federal and numeric work | No changes | Preserved |\n\n**Crosswalk rows: 12.**\n\n# 9. Complete correction-scope coverage\n\n| # | Required subquestion | Status | Claims / evidence | Exact remaining issue |\n| --- | --- | --- | --- | --- |\n| 1 | Correct case identity | Answered | C001; S001 heading | None as to the retrieved text’s stated citation |\n| 2 | Avoid different 92 Wis. 2d 175 case | Answered | C001 | No substitution made |\n| 3 | Actual opinion body rather than snippet | Answered | C001; S001 | Host is nonofficial |\n| 4 | Pages 164–65 | Read | C003; S001 page markers | No official page-image inspection |\n| 5 | Necessary preceding context | Read | C002; pp.149–50, 160–63 | No underlying private record |\n| 6 | Statutory language/version | Historical text read | C002; pp.160–62 | Biennial edition and current amendment chain not certified |\n| 7 | Majority holding | Answered | C003 | Governing modern route still must be established |\n| 8 | Dissent and joinder | Distinguished | C006 | No complete later treatment |\n| 9 | Timely winner’s confirmation predicate | Established in precedent | C002–C003 | Actual present application absent |\n| 10 | Responsive statutory objection | Supported | C003–C004 | Proper service and scheduling remain |\n| 11 | Independent late motion | Not authorized by this holding | C004 | Other authorities not resolved |\n| 12 | General fraud-discovery tolling | Not decided by this source | C007 | Separate controlling authority needed |\n| 13 | Merits outcome | Identified, not generalized | C005 | Consumer facts and award absent |\n| 14 | Current official annotation body | Not obtained | Source-status table | Earlier index remains only a lead |\n| 15 | Later published applying majority | Not relied upon | C008 | No absence-of-authority inference |\n| 16 | Current chapter 788 body | Not retried | C008 | Prior HTML/PDF failures retained |\n| 17 | Exact response deadline | Not created by case dates | C004 | Current service, order, and local rules |\n| 18 | Corrected C027 and dependent references | Completed in this supplement | C008; §§3–4, 8 | Coordinator review still separate |\n\n**Core coverage rows: 18.**\n\n# 10. Retained holds\n\n## Deferred verification and application\n\n| # | Hold | PASS-22 disposition |\n| --- | --- | --- |\n| D1 | Official reporter facsimile or judiciary-hosted 1979 copy | Not obtained; full public opinion reproduction read |\n| D2 | Complete current chapter 788 and linked service/computation rules | Existing access holds retained |\n| D3 | Complete subsequent history and citator | Not performed |\n| D4 | Fraud tolling, independent actions, and post-confirmation relief | Not decided |\n| D5 | Actual agreement, award, delivery, service, statutory ground, and confirmation posture | No private facts supplied or searched |\n| D6 | Publication, operations, component, state, A066/A097/A098, and parent acceptance | Expressly withheld |\n\n**Deferred rows: 6.**\n\n## Territorial/local boundaries\n\n| # | Branch | Limit |\n| --- | --- | --- |\n| T1 | Wisconsin courts and all 72 counties | Published Wisconsin holding researched; no county filing, briefing, service, or hearing practice certified |\n| T2 | Federal courts and FAA routes | P18 federal conclusions unchanged; historical federal cases cited by the 1979 majority are not a new current FAA certification |\n| T3 | Tribal, other-state, foreign, and Convention awards | No route or timing conclusion supplied |\n\n**Territorial/local rows: 3.**\n\n# Final audit\n\nThe new result is substantive but narrow: **the 1979 majority itself—not Brown County—supports the defensive-confirmation proposition.** C027 no longer depends solely on a later citation or annotation. The legal source’s public-host limitation and all present-application holds remain explicit.\n\n| Count unit | Result |\n| --- | --- |\n| New PASS-22 resource rows | **2** |\n| Successful new opinion-body reads | **1** |\n| Failed new public-reporter route | **1** |\n| Fresh limited checks of earlier registered sources | **0** |\n| Nonfresh source overlays | **3** |\n| Replacement original claim cells | **1 — S_WI-P18-C027** |\n| New PASS-22 atomic claims | **8** |\n| Correction-core coverage rows | **18** |\n| Deferred rows | **6** |\n| Territorial/local rows | **3** |\n| New fictional workflows | **2** |\n| Old-to-new crosswalk rows | **12** |\n\nPASS-18’s original **36 sources, 66 claims, 141 coverage rows, and 15 workflows** remain historical totals, not newly recounted or recertified material. P20’s earlier pending-source observation remains intact as provenance.\n\nNo actual party, litigation file, docket, creditor, arbitrator, provider, borrower, award, account, or private record was queried. The searches concerned the specifically authorized published precedent and public reporter routes only. No filing, contact, form, payment, local coordinator-file write, or publication occurred.\n\nThis supplement is not independent review, complete current-law certification, an actual timeliness or award-validity opinion, or acceptance of Wisconsin PASS-22 or the parent dossier.\n\nEND S_WI PASS-22\n\n","tables":[{"headers":["Material","PASS-22 result","Evidentiary classification"],"index":0,"links":[],"row_links":[[],[],[],[],[],[],[],[],[]],"rows":[["Material","PASS-22 result","Evidentiary classification"],["Milwaukee Police Association v. City of Milwaukee, 92 Wis. 2d 145, 285 N.W.2d 119 (1979)","Full opinion reproduction opened; majority, material context, and separate dissent read","Fresh published judicial opinion body on a nonofficial public host"],["Reporter pages 164–65","Read through the reproduction’s explicit reporter-page markers","Textual page verification, not pixel inspection of a reporter scan"],["Official court/reporter facsimile","Not obtained","Remaining format/authentication limit"],["Public reporter-library alternate","One reconstructed reporter locator failed","Failed retrieval, not absence of the opinion"],["Current official annotation body","Not obtained in this pass","Earlier P20 indexed annotation remains discovery only"],["Later published majority applying this exact exception","None opened and relied upon in this pass","No later-authority or complete-citator claim"],["Current chapter 788 HTML/PDF","Not retried","Prior access/currentness holds preserved"],["Brown County","Not reopened or relied upon","Existing historical-only classification preserved"]]},{"headers":["Event","Date stated in the opinion"],"index":1,"links":[],"row_links":[[],[],[],[],[],[]],"rows":[["Event","Date stated in the opinion"],["Arbitration award","October 20, 1976"],["Prevailing association’s court motion to confirm","March 29, 1977"],["City’s responsive motion to dismiss","April 7, 1977"],["Circuit court confirmation order","June 6, 1977"],["Judgment entered","July 21, 1977"]]},{"headers":["Field","Replacement"],"index":2,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Field","Replacement"],["Claim ID","S_WI-P18-C027"],["Area","A066; component and parent status remain open"],["Actor / predicate","Adverse arbitration party responding to the prevailing party’s timely court application to confirm, rather than independently initiating an otherwise late challenge"],["Precise assertion","In Milwaukee Police Association v. City of Milwaukee, 92 Wis. 2d 145, 164–65, 285 N.W.2d 119 (1979), the Wisconsin Supreme Court held under former §§298.09–298.13 that expiration of the three-month challenge period did not bar the adverse party’s responsive request to vacate, modify, or correct on statutory grounds."],["Required act / consequence","Raise a legally sufficient statutory objection in the confirmation proceeding through the proper response. The case does not supply a new universal response deadline, excuse defective service, or establish that the objection succeeds on its merits."],["Primary pinpoint","S_WI-P22-S001, majority pp.162–65, especially the final holding at p.165; procedural context pp.149–50"],["Source status","Published opinion body freshly read in a full public reproduction. Previous missing-body status is resolved at that level."],["Host / verification limit","Justia is not the official judiciary or bound reporter. No official reporter-page image was inspected."],["Currentness / application limit","The opinion applies former chapter 298. Existing chapter 788 current-body, governing-law, later-treatment, local-service, actual-award, and forum holds remain. No full modern FAA or other-jurisdiction conclusion is added."],["Exceptions / scope","Narrow confirmation-response posture. No fraud-discovery tolling holding and no unrestricted affirmative late-vacatur right."],["Review status","Research supplement only; not independent review or coordinator acceptance"]]},{"headers":["Original location","Replacement status","Evidence and remaining limit"],"index":3,"links":[],"row_links":[[],[],[],[],[],[],[]],"rows":[["Original location","Replacement status","Evidence and remaining limit"],["P18 core row 41 — Confirmation-response exception","Supported by freshly read published-opinion body, within stated historical/currentness limits","Corrected C027; P22-S001, pp.162–65"],["P18 core row 42 — Unlimited tolling","Unchanged: no unlimited-tolling rule established","C028 remains historical-only; the new opinion is not a fraud-tolling decision"],["P18 core row 82 — Fraud procurement","Unchanged","No fresh §788.10 body or fraud-proof analysis in this pass"],["P18 core row 83 — Fraud discovery timing","Unchanged: unresolved as a general tolling question","Corrected C053’s separation of procurement and timing remains"],["P20 core row 6 — Exact Milwaukee Police target","Exact target now opened","Correct citations and opinion identity verified from P22-S001"],["P20 core row 7 — C027 support pending","Opinion-text gap resolved by this supplement","P20’s earlier “pending” observation remains accurate as historical provenance; it is not rewritten"]]},{"headers":["PASS-18 workflow","Narrow annotation only"],"index":4,"links":[],"row_links":[[],[],[]],"rows":[["PASS-18 workflow","Narrow annotation only"],["Workflow 4 — late standalone notice","Its alternative involving a later timely confirmation request may now cite corrected C027 and P22-S001. That does not cure the standalone branch or establish a response deadline."],["Workflow 5 — fraud discovered after award","A genuine confirmation-response posture may invoke corrected C027, but discovery of fraud alone does not trigger this exception. Fraud tolling remains unresolved."]]},{"headers":["Source ID","Issuer/title/full literal URL","Edition, status, pinpoint","Actual reading and limits"],"index":5,"links":[],"row_links":[[],[],[]],"rows":[["Source ID","Issuer/title/full literal URL","Edition, status, pinpoint","Actual reading and limits"],["S_WI-P22-S001","Wisconsin Supreme Court opinion, publicly reproduced by Justia: Milwaukee Police Association v. City of Milwaukee, 92 Wis. 2d 145, 285 N.W.2d 119 (1979). https://law.justia.com/cases/wisconsin/supreme-court/1979/77-115-7.html","Decided November 6, 1979. Majority by Connor T. Hansen, J.; separate Abrahamson dissent joined by Day. Material reporter pages 149–50, 160–65; dissent 165–75. Former §§298.09–.13 quoted.","Fresh opinion body read, including the material majority, adjacent context, dissent, and relevant footnotes. This is judicial text, not the publisher’s summary. Host is nonofficial. HTML reporter markers read; PDF index not applicable; no reporter pixels inspected. No current statutory commencement or full citator certification."],["S_WI-P22-S002","Attempted public case-reporter library locator. https://cite.case.law/wis-2d/92/145/","Locator reconstructed from the exact reporter citation; no returned opinion title, edition, or pages could be validated","One failed fetch: inaccessible through the tool. No retry or workaround. This failure neither disproves the opinion nor authenticates a facsimile. The successful public reproduction in S001 supplies the text actually used."]]},{"headers":["Earlier source","Existing status preserved","PASS-22 treatment"],"index":6,"links":[],"row_links":[[],[],[],[]],"rows":[["Earlier source","Existing status preserved","PASS-22 treatment"],["S_WI-P20-S003 — https://docs.legis.wisconsin.gov/document/statutes/788.11%281%29%28c%29","Official indexed annotation lead only","Not reopened or upgraded. It no longer carries the burden of supplying the original holding."],["S_WI-P18-S024 — https://www.wicourts.gov/ca/opinion/DisplayDocument.html?content=html&seqNo=19110","Brown County: historical-only, pre-2009 unpublished per curiam","Not reopened or relied on as persuasive authority. C028’s limitation remains."],["S_WI-P18-S005 — https://law.justia.com/codes/wisconsin/chapter-788/section-788-10/","Prior nonofficial statutory read-aid with current-body hold","Not reread. C053’s procurement support and its separate timing hold are unchanged."]]},{"headers":["Claim ID","Actor / predicate","Atomic assertion or consequence","Source / pinpoint","Exception and remaining hold"],"index":7,"links":[],"row_links":[[],[],[],[],[],[],[],[],[]],"rows":[["Claim ID","Actor / predicate","Atomic assertion or consequence","Source / pinpoint","Exception and remaining hold"],["S_WI-P22-C001","Researcher identifying precedent","The exact 92 Wis. 2d 145 / 285 N.W.2d 119 opinion body was opened; the distinct page-175 case was not substituted","S001 heading and reporter identifiers","Nonofficial reproduction host; no official facsimile"],["C002","Court applying historical arbitration statutes","The case used former chapter 298 and involved a timely confirmation application followed by a responsive challenge","S001 pp.149–50, 160–63","Exact biennial edition not stated; current consolidation not verified"],["C003","Adverse party responding to winner’s confirmation request","Three-month expiration did not itself bar statutory vacatur/modification/correction grounds in that response posture","S001 pp.164–65, final majority holding","Proper response and statutory ground still required"],["C004","Party considering affirmative versus defensive relief","The holding does not create a general independent late-motion right or a new response deadline","S001 pp.162–65","Actual service, scheduling, finality, and posture remain unknown"],["C005","Reviewing court","The majority reversed confirmation after finding excess of arbitral authority","S001 pp.158–60, 165","Labor-contract merits are not transferred to a consumer award"],["C006","Reader distinguishing writings","Abrahamson’s strict-deadline approach, joined by Day, is dissent—not the holding","S001 pp.165–75","Disagreement does not itself establish later reversal"],["C007","Fraud-based challenger","This opinion does not decide discovery-of-fraud tolling","S001’s actual issues and timing analysis, pp.150, 160–65","C028/C053 timing limitations remain"],["C008","Registry/source-status reviewer","The original-opinion-text gap is resolved; official-facsimile, current-law, governing-route, and later-treatment holds remain","S001–S002; supplied P18/P20 record","No current all-source or actual-case certification"]]},{"headers":["#","P18/P20 location","PASS-22 change","Status"],"index":8,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["#","P18/P20 location","PASS-22 change","Status"],["1","S_WI-P18-C027, originally supported by “S024 ¶3; Milwaukee Police rule”","Replace with the complete cell in §3, supported directly by P22-S001","Opinion-body support obtained"],["2","P18 G1.11 confirmation-response paragraph","Replace source-pending sentence with direct majority support and retained limits","Narrow narrative replacement"],["3","P18 core row 41","Update from pending to supported within source/currentness bounds","Existing row only"],["4","P18 workflow 4 alternative","Add direct support for genuine confirmation-response posture","No date/model rerun"],["5","P18 workflow 5 alternative","Separate available response posture from unresolved fraud tolling","No new extension"],["6","P18 C028/core row 42","Preserve historical-only Brown County and no generalized tolling conclusion","Unchanged"],["7","P18 C053/core rows 82–83","Preserve procurement/timing separation","Unchanged"],["8","P18 S024","Remove no history; do not restore persuasive status","Unchanged source classification"],["9","P20 §2.2 and C027 pending cell","Append this successful opinion-body retrieval; preserve the earlier pending observation as accurate when made","New provenance layer"],["10","P20 core rows 6–7","Exact target obtained; original-text gap closed at public-reproduction level","Existing rows supplemented"],["11","P20 retained D2 source gap","Narrow remaining gap to official facsimile/current-law/later-treatment verification","Not complete acceptance"],["12","P20 Minerals, Jones, SC-6000, Sewart repairs; P18 federal and numeric work","No changes","Preserved"]]},{"headers":["#","Required subquestion","Status","Claims / evidence","Exact remaining issue"],"index":9,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["#","Required subquestion","Status","Claims / evidence","Exact remaining issue"],["1","Correct case identity","Answered","C001; S001 heading","None as to the retrieved text’s stated citation"],["2","Avoid different 92 Wis. 2d 175 case","Answered","C001","No substitution made"],["3","Actual opinion body rather than snippet","Answered","C001; S001","Host is nonofficial"],["4","Pages 164–65","Read","C003; S001 page markers","No official page-image inspection"],["5","Necessary preceding context","Read","C002; pp.149–50, 160–63","No underlying private record"],["6","Statutory language/version","Historical text read","C002; pp.160–62","Biennial edition and current amendment chain not certified"],["7","Majority holding","Answered","C003","Governing modern route still must be established"],["8","Dissent and joinder","Distinguished","C006","No complete later treatment"],["9","Timely winner’s confirmation predicate","Established in precedent","C002–C003","Actual present application absent"],["10","Responsive statutory objection","Supported","C003–C004","Proper service and scheduling remain"],["11","Independent late motion","Not authorized by this holding","C004","Other authorities not resolved"],["12","General fraud-discovery tolling","Not decided by this source","C007","Separate controlling authority needed"],["13","Merits outcome","Identified, not generalized","C005","Consumer facts and award absent"],["14","Current official annotation body","Not obtained","Source-status table","Earlier index remains only a lead"],["15","Later published applying majority","Not relied upon","C008","No absence-of-authority inference"],["16","Current chapter 788 body","Not retried","C008","Prior HTML/PDF failures retained"],["17","Exact response deadline","Not created by case dates","C004","Current service, order, and local rules"],["18","Corrected C027 and dependent references","Completed in this supplement","C008; §§3–4, 8","Coordinator review still separate"]]},{"headers":["#","Hold","PASS-22 disposition"],"index":10,"links":[],"row_links":[[],[],[],[],[],[],[]],"rows":[["#","Hold","PASS-22 disposition"],["D1","Official reporter facsimile or judiciary-hosted 1979 copy","Not obtained; full public opinion reproduction read"],["D2","Complete current chapter 788 and linked service/computation rules","Existing access holds retained"],["D3","Complete subsequent history and citator","Not performed"],["D4","Fraud tolling, independent actions, and post-confirmation relief","Not decided"],["D5","Actual agreement, award, delivery, service, statutory ground, and confirmation posture","No private facts supplied or searched"],["D6","Publication, operations, component, state, A066/A097/A098, and parent acceptance","Expressly withheld"]]},{"headers":["#","Branch","Limit"],"index":11,"links":[],"row_links":[[],[],[],[]],"rows":[["#","Branch","Limit"],["T1","Wisconsin courts and all 72 counties","Published Wisconsin holding researched; no county filing, briefing, service, or hearing practice certified"],["T2","Federal courts and FAA routes","P18 federal conclusions unchanged; historical federal cases cited by the 1979 majority are not a new current FAA certification"],["T3","Tribal, other-state, foreign, and Convention awards","No route or timing conclusion supplied"]]},{"headers":["Count unit","Result"],"index":12,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Count unit","Result"],["New PASS-22 resource rows","2"],["Successful new opinion-body reads","1"],["Failed new public-reporter route","1"],["Fresh limited checks of earlier registered sources","0"],["Nonfresh source overlays","3"],["Replacement original claim cells","1 — S_WI-P18-C027"],["New PASS-22 atomic claims","8"],["Correction-core coverage rows","18"],["Deferred rows","6"],["Territorial/local rows","3"],["New fictional workflows","2"],["Old-to-new crosswalk rows","12"]]}],"claims":[{"claim_id":"S_WI-P22-C001","area_numbers":[66],"area_assignment_method":"literal_pass_scope","researcher_record":{"Claim ID":"S_WI-P22-C001","Actor / predicate":"Researcher identifying precedent","Atomic assertion or consequence":"The exact 92 Wis. 2d 145 / 285 N.W.2d 119 opinion body was opened; the distinct page-175 case was not substituted","Source / pinpoint":"S001 heading and reporter identifiers","Exception and remaining hold":"Nonofficial reproduction host; no official facsimile"},"raw_table_index":7,"coordinator_verification_status":"selected_primary_body_checked_with_retained_holds"},{"claim_id":"S_WI-P22-C002","area_numbers":[66],"area_assignment_method":"literal_pass_scope","researcher_record":{"Claim ID":"C002","Actor / predicate":"Court applying historical arbitration statutes","Atomic assertion or consequence":"The case used former chapter 298 and involved a timely confirmation application followed by a responsive challenge","Source / pinpoint":"S001 pp.149–50, 160–63","Exception and remaining hold":"Exact biennial edition not stated; current consolidation not verified"},"raw_table_index":7,"coordinator_verification_status":"selected_primary_body_checked_with_retained_holds"},{"claim_id":"S_WI-P22-C003","area_numbers":[66],"area_assignment_method":"literal_pass_scope","researcher_record":{"Claim ID":"C003","Actor / predicate":"Adverse party responding to winner’s confirmation request","Atomic assertion or consequence":"Three-month expiration did not itself bar statutory vacatur/modification/correction grounds in that response posture","Source / pinpoint":"S001 pp.164–65, final majority holding","Exception and remaining hold":"Proper response and statutory ground still required"},"raw_table_index":7,"coordinator_verification_status":"selected_primary_body_checked_with_retained_holds"},{"claim_id":"S_WI-P22-C004","area_numbers":[66],"area_assignment_method":"literal_pass_scope","researcher_record":{"Claim ID":"C004","Actor / predicate":"Party considering affirmative versus defensive relief","Atomic assertion or consequence":"The holding does not create a general independent late-motion right or a new response deadline","Source / pinpoint":"S001 pp.162–65","Exception and remaining hold":"Actual service, scheduling, finality, and posture remain unknown"},"raw_table_index":7,"coordinator_verification_status":"selected_primary_body_checked_with_retained_holds"},{"claim_id":"S_WI-P22-C005","area_numbers":[66],"area_assignment_method":"literal_pass_scope","researcher_record":{"Claim ID":"C005","Actor / predicate":"Reviewing court","Atomic assertion or consequence":"The majority reversed confirmation after finding excess of arbitral authority","Source / pinpoint":"S001 pp.158–60, 165","Exception and remaining hold":"Labor-contract merits are not transferred to a consumer award"},"raw_table_index":7,"coordinator_verification_status":"selected_primary_body_checked_with_retained_holds"},{"claim_id":"S_WI-P22-C006","area_numbers":[66],"area_assignment_method":"literal_pass_scope","researcher_record":{"Claim ID":"C006","Actor / predicate":"Reader distinguishing writings","Atomic assertion or consequence":"Abrahamson’s strict-deadline approach, joined by Day, is dissent—not the holding","Source / pinpoint":"S001 pp.165–75","Exception and remaining hold":"Disagreement does not itself establish later reversal"},"raw_table_index":7,"coordinator_verification_status":"selected_primary_body_checked_with_retained_holds"},{"claim_id":"S_WI-P22-C007","area_numbers":[66],"area_assignment_method":"literal_pass_scope","researcher_record":{"Claim ID":"C007","Actor / predicate":"Fraud-based challenger","Atomic assertion or consequence":"This opinion does not decide discovery-of-fraud tolling","Source / pinpoint":"S001’s actual issues and timing analysis, pp.150, 160–65","Exception and remaining hold":"C028/C053 timing limitations remain"},"raw_table_index":7,"coordinator_verification_status":"selected_primary_body_checked_with_retained_holds"},{"claim_id":"S_WI-P22-C008","area_numbers":[66],"area_assignment_method":"literal_pass_scope","researcher_record":{"Claim ID":"C008","Actor / predicate":"Registry/source-status reviewer","Atomic assertion or consequence":"The original-opinion-text gap is resolved; official-facsimile, current-law, governing-route, and later-treatment holds remain","Source / pinpoint":"S001–S002; supplied P18/P20 record","Exception and remaining hold":"No current all-source or actual-case certification"},"raw_table_index":7,"coordinator_verification_status":"selected_primary_body_checked_with_retained_holds"},{"claim_id":"S_WI-P18-C027","area_numbers":[66],"area_assignment_method":"literal_original_claim_replacement","researcher_record":{"Claim ID":"S_WI-P18-C027","Area":"A066; component and parent status remain open","Actor / predicate":"Adverse arbitration party responding to the prevailing party’s timely court application to confirm, rather than independently initiating an otherwise late challenge","Precise assertion":"In Milwaukee Police Association v. City of Milwaukee, 92 Wis. 2d 145, 164–65, 285 N.W.2d 119 (1979), the Wisconsin Supreme Court held under former §§298.09–298.13 that expiration of the three-month challenge period did not bar the adverse party’s responsive request to vacate, modify, or correct on statutory grounds.","Required act / consequence":"Raise a legally sufficient statutory objection in the confirmation proceeding through the proper response. The case does not supply a new universal response deadline, excuse defective service, or establish that the objection succeeds on its merits.","Primary pinpoint":"S_WI-P22-S001, majority pp.162–65, especially the final holding at p.165; procedural context pp.149–50","Source status":"Published opinion body freshly read in a full public reproduction. Previous missing-body status is resolved at that level.","Host / verification limit":"Justia is not the official judiciary or bound reporter. No official reporter-page image was inspected.","Currentness / application limit":"The opinion applies former chapter 298. Existing chapter 788 current-body, governing-law, later-treatment, local-service, actual-award, and forum holds remain. No full modern FAA or other-jurisdiction conclusion is added.","Exceptions / scope":"Narrow confirmation-response posture. No fraud-discovery tolling holding and no unrestricted affirmative late-vacatur right.","Review status":"Research supplement only; not independent review or coordinator acceptance"},"raw_table_index":2,"replacement_of":"S_WI/pass-18/C027","coordinator_verification_status":"published_opinion_text_checked;not_current_law_or_actual_case_acceptance"}],"sources":[{"source_id":"S_WI-P22-S001","urls":["https://law.justia.com/cases/wisconsin/supreme-court/1979/77-115-7.html"],"researcher_record":{"Source ID":"S_WI-P22-S001","Issuer/title/full literal URL":"Wisconsin Supreme Court opinion, publicly reproduced by Justia: Milwaukee Police Association v. City of Milwaukee, 92 Wis. 2d 145, 285 N.W.2d 119 (1979). https://law.justia.com/cases/wisconsin/supreme-court/1979/77-115-7.html","Edition, status, pinpoint":"Decided November 6, 1979. Majority by Connor T. Hansen, J.; separate Abrahamson dissent joined by Day. Material reporter pages 149–50, 160–65; dissent 165–75. Former §§298.09–.13 quoted.","Actual reading and limits":"Fresh opinion body read, including the material majority, adjacent context, dissent, and relevant footnotes. This is judicial text, not the publisher’s summary. Host is nonofficial. HTML reporter markers read; PDF index not applicable; no reporter pixels inspected. No current statutory commencement or full citator certification."},"coordinator_verification_status":"not_yet_checked"},{"source_id":"S_WI-P22-S002","urls":["https://cite.case.law/wis-2d/92/145/"],"researcher_record":{"Source ID":"S_WI-P22-S002","Issuer/title/full literal URL":"Attempted public case-reporter library locator. https://cite.case.law/wis-2d/92/145/","Edition, status, pinpoint":"Locator reconstructed from the exact reporter citation; no returned opinion title, edition, or pages could be validated","Actual reading and limits":"One failed fetch: inaccessible through the tool. No retry or workaround. This failure neither disproves the opinion nor authenticates a facsimile. The successful public reproduction in S001 supplies the text actually used."},"coordinator_verification_status":"not_yet_checked"}],"coverage":[{"topic":"1 Correct case identity","researcher_record":{"#":"1","Required subquestion":"Correct case identity","Status":"Answered","Claims / evidence":"C001; S001 heading","Exact remaining issue":"None as to the retrieved text’s stated citation"},"raw_table_index":9,"coordinator_acceptance":"scoped_source_gap_reviewed;current_law_local_private_parent_not_accepted"},{"topic":"2 Avoid different 92 Wis. 2d 175 case","researcher_record":{"#":"2","Required subquestion":"Avoid different 92 Wis. 2d 175 case","Status":"Answered","Claims / evidence":"C001","Exact remaining issue":"No substitution made"},"raw_table_index":9,"coordinator_acceptance":"scoped_source_gap_reviewed;current_law_local_private_parent_not_accepted"},{"topic":"3 Actual opinion body rather than snippet","researcher_record":{"#":"3","Required subquestion":"Actual opinion body rather than snippet","Status":"Answered","Claims / evidence":"C001; S001","Exact remaining issue":"Host is nonofficial"},"raw_table_index":9,"coordinator_acceptance":"scoped_source_gap_reviewed;current_law_local_private_parent_not_accepted"},{"topic":"4 Pages 164–65","researcher_record":{"#":"4","Required subquestion":"Pages 164–65","Status":"Read","Claims / evidence":"C003; S001 page markers","Exact remaining issue":"No official page-image inspection"},"raw_table_index":9,"coordinator_acceptance":"scoped_source_gap_reviewed;current_law_local_private_parent_not_accepted"},{"topic":"5 Necessary preceding context","researcher_record":{"#":"5","Required subquestion":"Necessary preceding context","Status":"Read","Claims / evidence":"C002; pp.149–50, 160–63","Exact remaining issue":"No underlying private record"},"raw_table_index":9,"coordinator_acceptance":"scoped_source_gap_reviewed;current_law_local_private_parent_not_accepted"},{"topic":"6 Statutory language/version","researcher_record":{"#":"6","Required subquestion":"Statutory language/version","Status":"Historical text read","Claims / evidence":"C002; pp.160–62","Exact remaining issue":"Biennial edition and current amendment chain not certified"},"raw_table_index":9,"coordinator_acceptance":"scoped_source_gap_reviewed;current_law_local_private_parent_not_accepted"},{"topic":"7 Majority holding","researcher_record":{"#":"7","Required subquestion":"Majority holding","Status":"Answered","Claims / evidence":"C003","Exact remaining issue":"Governing modern route still must be established"},"raw_table_index":9,"coordinator_acceptance":"scoped_source_gap_reviewed;current_law_local_private_parent_not_accepted"},{"topic":"8 Dissent and joinder","researcher_record":{"#":"8","Required subquestion":"Dissent and joinder","Status":"Distinguished","Claims / evidence":"C006","Exact remaining issue":"No complete later treatment"},"raw_table_index":9,"coordinator_acceptance":"scoped_source_gap_reviewed;current_law_local_private_parent_not_accepted"},{"topic":"9 Timely winner’s confirmation predicate","researcher_record":{"#":"9","Required subquestion":"Timely winner’s confirmation predicate","Status":"Established in precedent","Claims / evidence":"C002–C003","Exact remaining issue":"Actual present application absent"},"raw_table_index":9,"coordinator_acceptance":"scoped_source_gap_reviewed;current_law_local_private_parent_not_accepted"},{"topic":"10 Responsive statutory objection","researcher_record":{"#":"10","Required subquestion":"Responsive statutory objection","Status":"Supported","Claims / evidence":"C003–C004","Exact remaining issue":"Proper service and scheduling remain"},"raw_table_index":9,"coordinator_acceptance":"scoped_source_gap_reviewed;current_law_local_private_parent_not_accepted"},{"topic":"11 Independent late motion","researcher_record":{"#":"11","Required subquestion":"Independent late motion","Status":"Not authorized by this holding","Claims / evidence":"C004","Exact remaining issue":"Other authorities not resolved"},"raw_table_index":9,"coordinator_acceptance":"scoped_source_gap_reviewed;current_law_local_private_parent_not_accepted"},{"topic":"12 General fraud-discovery tolling","researcher_record":{"#":"12","Required subquestion":"General fraud-discovery tolling","Status":"Not decided by this source","Claims / evidence":"C007","Exact remaining issue":"Separate controlling authority needed"},"raw_table_index":9,"coordinator_acceptance":"scoped_source_gap_reviewed;current_law_local_private_parent_not_accepted"},{"topic":"13 Merits outcome","researcher_record":{"#":"13","Required subquestion":"Merits outcome","Status":"Identified, not generalized","Claims / evidence":"C005","Exact remaining issue":"Consumer facts and award absent"},"raw_table_index":9,"coordinator_acceptance":"scoped_source_gap_reviewed;current_law_local_private_parent_not_accepted"},{"topic":"14 Current official annotation body","researcher_record":{"#":"14","Required subquestion":"Current official annotation body","Status":"Not obtained","Claims / evidence":"Source-status table","Exact remaining issue":"Earlier index remains only a lead"},"raw_table_index":9,"coordinator_acceptance":"scoped_source_gap_reviewed;current_law_local_private_parent_not_accepted"},{"topic":"15 Later published applying majority","researcher_record":{"#":"15","Required subquestion":"Later published applying majority","Status":"Not relied upon","Claims / evidence":"C008","Exact remaining issue":"No absence-of-authority inference"},"raw_table_index":9,"coordinator_acceptance":"scoped_source_gap_reviewed;current_law_local_private_parent_not_accepted"},{"topic":"16 Current chapter 788 body","researcher_record":{"#":"16","Required subquestion":"Current chapter 788 body","Status":"Not retried","Claims / evidence":"C008","Exact remaining issue":"Prior HTML/PDF failures retained"},"raw_table_index":9,"coordinator_acceptance":"scoped_source_gap_reviewed;current_law_local_private_parent_not_accepted"},{"topic":"17 Exact response deadline","researcher_record":{"#":"17","Required subquestion":"Exact response deadline","Status":"Not created by case dates","Claims / evidence":"C004","Exact remaining issue":"Current service, order, and local rules"},"raw_table_index":9,"coordinator_acceptance":"scoped_source_gap_reviewed;current_law_local_private_parent_not_accepted"},{"topic":"18 Corrected C027 and dependent references","researcher_record":{"#":"18","Required subquestion":"Corrected C027 and dependent references","Status":"Completed in this supplement","Claims / evidence":"C008; §§3–4, 8","Exact remaining issue":"Coordinator review still separate"},"raw_table_index":9,"coordinator_acceptance":"scoped_source_gap_reviewed;current_law_local_private_parent_not_accepted"},{"topic":"D1 Official reporter facsimile or judiciary-hosted 1979 copy","researcher_record":{"#":"D1","Hold":"Official reporter facsimile or judiciary-hosted 1979 copy","PASS-22 disposition":"Not obtained; full public opinion reproduction read"},"raw_table_index":10,"coordinator_acceptance":"scoped_source_gap_reviewed;current_law_local_private_parent_not_accepted"},{"topic":"D2 Complete current chapter 788 and linked service/computation rules","researcher_record":{"#":"D2","Hold":"Complete current chapter 788 and linked service/computation rules","PASS-22 disposition":"Existing access holds retained"},"raw_table_index":10,"coordinator_acceptance":"scoped_source_gap_reviewed;current_law_local_private_parent_not_accepted"},{"topic":"D3 Complete subsequent history and citator","researcher_record":{"#":"D3","Hold":"Complete subsequent history and citator","PASS-22 disposition":"Not performed"},"raw_table_index":10,"coordinator_acceptance":"scoped_source_gap_reviewed;current_law_local_private_parent_not_accepted"},{"topic":"D4 Fraud tolling, independent actions, and post-confirmation relief","researcher_record":{"#":"D4","Hold":"Fraud tolling, independent actions, and post-confirmation relief","PASS-22 disposition":"Not decided"},"raw_table_index":10,"coordinator_acceptance":"scoped_source_gap_reviewed;current_law_local_private_parent_not_accepted"},{"topic":"D5 Actual agreement, award, delivery, service, statutory ground, and confirmation posture","researcher_record":{"#":"D5","Hold":"Actual agreement, award, delivery, service, statutory ground, and confirmation posture","PASS-22 disposition":"No private facts supplied or searched"},"raw_table_index":10,"coordinator_acceptance":"scoped_source_gap_reviewed;current_law_local_private_parent_not_accepted"},{"topic":"D6 Publication, operations, component, state, A066/A097/A098, and parent acceptance","researcher_record":{"#":"D6","Hold":"Publication, operations, component, state, A066/A097/A098, and parent acceptance","PASS-22 disposition":"Expressly withheld"},"raw_table_index":10,"coordinator_acceptance":"scoped_source_gap_reviewed;current_law_local_private_parent_not_accepted"},{"topic":"T1 Wisconsin courts and all 72 counties","researcher_record":{"#":"T1","Branch":"Wisconsin courts and all 72 counties","Limit":"Published Wisconsin holding researched; no county filing, briefing, service, or hearing practice certified"},"raw_table_index":11,"coordinator_acceptance":"scoped_source_gap_reviewed;current_law_local_private_parent_not_accepted"},{"topic":"T2 Federal courts and FAA routes","researcher_record":{"#":"T2","Branch":"Federal courts and FAA routes","Limit":"P18 federal conclusions unchanged; historical federal cases cited by the 1979 majority are not a new current FAA certification"},"raw_table_index":11,"coordinator_acceptance":"scoped_source_gap_reviewed;current_law_local_private_parent_not_accepted"},{"topic":"T3 Tribal, other-state, foreign, and Convention awards","researcher_record":{"#":"T3","Branch":"Tribal, other-state, foreign, and Convention awards","Limit":"No route or timing conclusion supplied"},"raw_table_index":11,"coordinator_acceptance":"scoped_source_gap_reviewed;current_law_local_private_parent_not_accepted"}],"annotations":{},"corrections":[],"resolved_corrections":[],"review_history":[]}