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Explore Wisconsin information →This address preserves a dated source document behind the guide. The complete explanation covers the questions, comparisons and next steps for this subject.
If you came here to check a specific citation, open the original archive below. It includes its source dates and recorded qualifications.
The explanation above is written for readers. These original working documents preserve the evidence trail, including technical language, dated passages and known corrections. They have not all received independent professional review. Use the marked limits before relying on a particular rule or figure.
Read the evidence with its boundaries. These are saved research components, including revisions. A scoped coordinator review checks selected evidence; it does not certify every claim, a complete jurisdiction, current law or individual applicability. Dates and access limits remain attached to the records.
These components repair their stated scope. They do not replace every other finding in this research series.
Four bounded qualification repairs to reviewed →Fresh access date: October 26, 2026, America/Los_Angeles; October 27, 2026 UTC. Individual source-opening clock times are not asserted.
Scope: This corrects PASS-17’s treatment of unpublished Wisconsin opinions and the claims dependent on those sources.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.
Disposition: The blanket statement that all PASS-17 sources S022–S027 are available as persuasive authority is withdrawn.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.
The Wisconsin Supreme Court’s 2009 WI 2, entered January 6, 2009 and effective July 1, 2009, amended Rule 809.23(3) as follows:
| 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| (3)(a) | Unpublished opinions ordinarily cannot be cited in Wisconsin courts as precedent or authority.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. |
New claims S_WI-P19-C001–C005. Primary authority: https://www.wicourts.gov/sc/scord/DisplayDocument.html?content=html&seqNo=35116, §§1–3, amending Rule 809.23(3)(a)–(c). Wisconsin Court System
The 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.
https://www.wicourts.gov/opinions/appeals2.htm, headings “Precedential value of opinions” and “Citation of unpublished opinions.” Wisconsin Court System
The supplied current Legislature endpoint was attempted once in this pass and timed out:
https://docs.legis.wisconsin.gov/statutes/statutes/809/iii/23/3
The 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)
The 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.
Old assertion: “Unpublished cases are persuasive, not precedential.” Old actor: Appellate researcher. Old sources: S_WI-P17-S022–S027. Old qualification: “Published authority controls.”
Correct replacement:
S_WI-P17-C050 — Citation status of unpublished Wisconsin opinions. A 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.
Authority: S_WI-P19-S001, Rule 809.23(3)(a)–(c); S_WI-P19-S002. Currentness limit: Complete current integrated rule and full subsequent-history review remain held. Registry status: A066/A097/A098 open; no acceptance. Wisconsin Court System+1
Old assertion: “Unpublished Benitez supports distinct §806.07(d) theory.” Old actor: Void-service challenger. Old source: S_WI-P17-S024. Old qualification: “Persuasive only.”
Correct replacement:
S_WI-P17-C027 — Historical Benitez discussion, not ordinary persuasive authority. PASS-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.
Sources: Historical S_WI-P17-S024; citation rule S_WI-P19-S001; limited fresh Ripco check under existing S_WI-P17-S023. Effect: Withdraw the legal-support status, not the historical source record or its historical outcome. Registry status: A066/A097/A098 open; no actual judgment is declared void. Wisconsin Court System+1
The 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.
| 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. |
The fresh Ryan and Ripco documents visibly establish named authorship and nonpublication. Their citation eligibility does not enlarge their holdings. Wisconsin Court System+3
The following replacements remove the three pre-2009 opinions from ordinary persuasive support. Existing statutory/currentness holds remain.
| 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. |
The 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
| 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. |
The 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.
Benitez 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.
Unpublished 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.
The 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.
These 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.
| 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. Wisconsin 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. Wisconsin 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) |
New resource rows: 3—two successful body reads and one failed current-body route.
| 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 |
New correction claims: 11.
These are 17 existing coverage rows, not new coverage added to the original 139-row history.
| 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 |
| # | 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 |
Crosswalk rows: 15.
A 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.
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
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.
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.
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.
A hypothetical researcher considers Ryan v. Friday, No. 2018AP1354, for a Wisconsin memorandum addressing a failure to attend a small-claims hearing.
The 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
Its 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.
If 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
Remaining limit: Later treatment and the actual matter’s facts are not reviewed. No brief was prepared or filed.
| # | 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 |
Correction-core rows: 20.
| # | 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 |
Deferred rows: 6.
| # | 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. |
Territorial/local rows: 3.
| 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 |
The 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.
The 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.
The 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.
No 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.
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.
END S_WI PASS-19
Captured cells with original header handling and explicitly labeled bounded correction overlays. Downloaded JSON retains original cells. Tables may contain source limitations, historical examples and identified corrections; the complete reading supplies context.
Read the evidence with its boundaries. These are saved research components, including revisions. A scoped coordinator review checks selected evidence; it does not certify every claim, a complete jurisdiction, current law or individual applicability. Dates and access limits remain attached to the records.
These components repair their stated scope. They do not replace every other finding in this research series.
Four bounded qualification repairs to reviewed →Provision · Rule established by the order · 5 data 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. |
Existing source ID · Official document and exact URL · Corrected citation status and substantive limit · 6 data 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. |
Full PASS-17 claim ID · Corrected actor/predicate/assertion and consequence · Properly qualified support · 10 data 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. |
Existing source · Exact retained source and pinpoint · Narrow role retained · 4 data 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. |
Source ID · Issuer/title and full literal URL · Pinpoint, version, commencement · 3 data 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. Wisconsin 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. Wisconsin 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) |
Claim ID · A066/A097/A098 status · Actor/predicate · 11 data 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 |
Original P17 coverage row · Replacement status/finding · Corrected claim support · 17 data 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 |
# · PASS-17 item · PASS-19 change · 15 data 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 |
# · Correction issue · Status · 20 data 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 |
# · Hold retained · PASS-19 effect · 6 data 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 |
# · Scope · Limit · 3 data 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. |
Unit · Count/status · 14 data 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 |
Read the evidence with its boundaries. These are saved research components, including revisions. A scoped coordinator review checks selected evidence; it does not certify every claim, a complete jurisdiction, current law or individual applicability. Dates and access limits remain attached to the records.
These components repair their stated scope. They do not replace every other finding in this research series.
Four bounded qualification repairs to reviewed →Recorded check status: scoped correction checked with remaining holds
Recorded check status: scoped correction checked with remaining holds
Recorded check status: scoped correction checked with remaining holds
Recorded check status: scoped correction checked with remaining holds
Recorded check status: scoped correction checked with remaining holds
Recorded check status: scoped correction checked with remaining holds
Recorded check status: scoped correction checked with remaining holds
Recorded check status: scoped correction checked with remaining holds
Recorded check status: scoped correction checked with remaining holds
Recorded check status: scoped correction checked with remaining holds
Recorded check status: scoped correction checked with remaining holds
Recorded check status: scoped replacement checked with remaining holds
Recorded check status: scoped replacement checked with remaining holds
Recorded check status: scoped replacement checked with remaining holds
Recorded check status: scoped replacement checked with remaining holds
Recorded check status: scoped replacement checked with remaining holds
Recorded check status: scoped replacement checked with remaining holds
Recorded check status: scoped replacement checked with remaining holds
Recorded check status: scoped replacement checked with remaining holds
Recorded check status: scoped replacement checked with remaining holds
Recorded check status: scoped replacement checked with remaining holds
Recorded check status: scoped replacement checked with remaining holds
Recorded check status: scoped replacement checked with remaining holds
Keep the source version, actual read extent and jurisdiction with the proposition. A link or researcher access claim is not a substitute for an operative primary passage.
Recorded check status: checked against precisely dated P17 coordinator record with retained limits
Recorded check status: checked against precisely dated P17 coordinator record with retained limits
Recorded check status: checked against precisely dated P17 coordinator record with retained limits
Recorded check status: checked against precisely dated P17 coordinator record with retained limits
Recorded check status: checked against precisely dated P17 coordinator record with retained limits
The saved component-level coverage record keeps answered, partial, blank and unresolved branches distinct. A coverage label is not acceptance of a whole subject or jurisdiction.
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Recorded check status: recorded; no individual primary acceptance inferred
Read the evidence with its boundaries. These are saved research components, including revisions. A scoped coordinator review checks selected evidence; it does not certify every claim, a complete jurisdiction, current law or individual applicability. Dates and access limits remain attached to the records.
No currently queued material correction is mapped to this component. This does not remove its currentness, access, jurisdiction or application limits.
P17pre2009citation and dependent support repairs addressed with holds
Inside: Executive disposition · 1. Classification of the covered business models · 1.1 Statutory definition
Inside: Important access limitation · 1. Governing classification architecture · 1.1 The three Wisconsin layers
Inside: Wisconsin prelitigation debt validation, disputes, and consumer access to account documentation · State-source access limitation · 1. Wisconsin Consumer Act gateway
Inside: Credit reporting, disputed information, settlements, and reporting consequences · 1. Critical current-law findings · The 2025 federal medical-debt reporting ban is not operative
Inside: G1. Corrected federal predicates and exceptions · 1. Regulation F §1006.30(b): paid, settled, and discharged debts · Separate §1006.30(a) debt-parking rule
Inside: G1. Exact Regulation F predicates and exceptions · 1. Replace PASS-05 C001's inconsistent conditions cell · 3. Two bounded classification comparisons
Inside: Executive findings · 1. Federal §501(r) actor and facility gateway · Actor / service classification matrix
Inside: Wisconsin ordinary civil money judgments: entry, docketing, liens, enforceability, renewal, interest, payments, and satisfaction · Wisconsin primary-text access qualification · 1. Rendition, entry, perfection, and docketing
Inside: Federal identity-theft credit-report blocking, fraud alerts, ordinary security freezes, and protected-consumer freezes · 1. Actor and route matrix · 2. The complete four-element block packet
Inside: Four bounded corrections to Wisconsin PASS-08 · Correct source-status classification · Replacement for PASS-08 §19.1
Inside: Wisconsin ordinary consumer-judgment earnings garnishment · 1. Covered proceeding · 2. Statutory actors
Inside: Four bounded qualification repairs to reviewed PASS-09 · 1. Replacement for PASS-09 paragraph 3 and S_WI-P09-C005 · Exact Regulation V sequence
Inside: Wisconsin ordinary consumer-judgment non-earnings garnishment of bank/deposit accounts and exempt-funds gateway · 1. Actor and legal-role matrix · 2. Separate-action and postjudgment gateway
Inside: Wisconsin ordinary civil money-judgment personal-property execution, levy, and sheriff-sale gateway · 1. Execution is court process, not self-help · 2. Core actors
Inside: Wisconsin homestead and ordinary personal-property exemption amounts, eligibility, and valuation gateway · Current principal amounts · 1. Constitutional and statutory construction
Inside: Wisconsin ordinary consumer money-debt small-claims commencement, service, appearance/answer, default, and necessary merits-proof gateway · Categories that must remain separate · 2. Future threshold
Inside: Wisconsin small-claims motion to reopen or vacate an ordinary consumer money-debt judgment · 1. Chapter 799 controls the special small-claims route · 2. Ordinary motion under §799.29
Inside: Wisconsin arbitration-award confirmation, vacatur, modification, and judgment gateway · The four principal Wisconsin stages · A court does not conduct an ordinary appeal from the award
Inside: Bounded citation-status and claim-traceability repair to PASS-18 · 2.1 Replacement source status: S_WI-P18-S024 · 2.2 The Milwaukee Police source gap
Inside: Wisconsin ordinary-civil default-judgment relief under §806.07 · 2.1 What kind of default is involved? · 2.2 Who can seek relief?
Inside: Narrow supplement: the 1979 Milwaukee Police confirmation-response holding · 2.1 Majority holding at pages 164–65 · 2.2 Actual procedural context
Inside: Motion-made, hearing-notice computation, electronic-service qualifications, and Mikrut date correction · 1.1 The central current-primary gap is not closed · 1.2 Limited primary electronic-filing support was obtained
Original saved Markdown SHA-256: 3b060ced1dedae8122cd1b2db5727211dbc7ebdcd994bd89d1ae7f4d92864be3. Public formatting, private-reference removal and correction annotations are separate from that immutable original.