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  • May 10, 2022

    Prescriptive Easements: Overhead to Underground

    On easements, whose rights take precedence – utility companies or private landowners? A recent decision by the Wisconsin Supreme Court effectively cements judicial interpretation of the statute and precedent in a clear and meaningful way.

    Andrew J. Lawton & Erik H. Monson


    Every first-year law student learns about the concept of adverse possession. On the outskirts of these lessons are rules regarding easements. In Wisconsin, these two concepts combine when it comes to utility companies and the placement of their equipment to deliver energy and telecommunications.

    About Easements

    An easement is the grant of a nonpossessory property interest that grants an easement holder permission for the use of another person’s property for a limited and specific purpose.1 Easements, therefore, differ from adverse possession, in that they are not created for the purpose of transferring ownership.

    Erik Monson Erik Monson, Ohio State 1998, is a shareholder with Coyne, Schultz, Becker & Bauer in Madison, where he focuses on civil litigation.

    Andrew Lawton Andrew Lawton, Marquette 2018, is an associate with Coyne, Schultz, Becker & Bauer in Madison, where he focuses on civil litigation.

    There are different kinds and types of easements. Affirmative easements give an easement holder the right to use the land of another, such as a road or passageway.2 A negative easement allows the easement holder to prevent the owner of land from using the land in a specific way, like building a structure or removing natural features.3 Easements generally need to be recorded with local governments, and in Wisconsin, easements need to also be re-recorded, the date of which depends on when the original easement was granted.4

    A prescriptive easement is a form of affirmative easement by use.5 A person who makes continuous, adverse use of the rights of the land (like using a path through the property) of another for a certain period (20 years in Wisconsin) can commence an action to establish a prescriptive right to continue to use the property of another in that capacity. Prescriptive rights too, the Wisconsin Court of Appeals has held, must also be periodically recorded to maintain their use.6

    Utility Services and Private Land Rights

    But with the vast amount of utility infrastructure crisscrossing every community in the state, what rules govern the use of land on which an electrical box or telephone pole sits, or overhead wires are strung? Must a utility track and record easements for the countless properties it operates on, under or over to provide critical services?

    The Wisconsin Legislature sought to eliminate these thorny issues by providing a statutory framework that strongly favored the public policy needs of utility service over private land rights. It is only relatively recently that this issue has been tested in Wisconsin appellate courts which, as described below, lay an even stronger groundwork for the public interest in keeping, upgrading, and maintaining utility infrastructure.

    A property owner who is aware of the use of their property by a utility (with or without their permission) has two options:

    • either tell the utility to remove all their equipment before 10 years from the date of that equipment’s installation; or

    • forever forfeit the ability to remove the prescriptive easement rights of the utility company.

    The spatial “footprint” of that prescriptive easement remains even in cases where, for instance, a utility company completely transfers its electrical equipment in that space from overhead poles to underground electrical lines.

    On Wis. Stat. Section 893.28 and Prescriptive Easements

    Wis. Stat. section 893.28, titled “Prescriptive rights by adverse user,” provides:

    (1) Continuous adverse use of rights in real estate of another for at least 20 years, except as provided in s. 893.29 establishes the prescriptive right to continue the use. Any person who in connection with his or her predecessor in interest has made continuous adverse use of rights in the land of another for 20 years, except as provided by s. 893.29, may commence an action to establish prescriptive rights under ch. 843.
    (2) Continuous use of rights in real estate of another for at least 10 years by a domestic corporation organized to furnish telegraph or telecommunications service or transmit heat, power or electric current to the public or for public purposes, by a cooperative association organized under ch. 185 or 193 to furnish telegraph or telecommunications service, or by a cooperative organized under ch. 185 to transmit heat, power or electric current to its members, establishes the prescriptive right to continue the use, except as provided by s. 893.29. A person who has established a prescriptive right under this subsection may commence an action to establish prescriptive rights under ch. 843.
    (3) The mere use of a way over unenclosed land is presumed to be permissive and not adverse.

    Only subsection (2) of this statute is relevant for the discussion of prescriptive easements and utilities, as this subsection contains critical distinctions from not only subsection (1), but also the general principles of adverse possession. Subsection (1) and adverse possession could be used by any person in the state, so long as that use is adverse to the interest of the property owner and for a period of 20 years. Subsection (2) exclusively applies to utility companies and the provision of their services.

    Subsection (2) states that if a utility furnishing electricity, power, heat, or telecommunications services for public use makes continuous use of any private property for 10 years even without permission, that utility has established a prescriptive right to continue the use of the property for that purpose and without a requirement to record the use with local government that carries the risk of expiration.

    This right of use continues even if a utility company removes overhead equipment and places it underground, so long as it is within the same general spatial “footprint” and does not dramatically impede on the land’s use.

    Since its enactment in 1979, the statute has only been amended twice with minor additions to broaden or modernize the organizational inclusion of a domestic corporation under subsection (2).

    The Long Wait for Precedent: Williams v. American Transmission Company

    Although the statute has been essentially unchanged since 1979, there was a gap between the enactment of the statute and the first published appellate decision discussing Wis. Stat. section 893.28(2).

    That decision finally came from the Wisconsin Court of Appeals in Williams v. American Transmission Company, LLC.7 The decision framed the issues for all future litigation in the state on the topic of prescriptive easements and utilities, and allowed other Wisconsin courts to meaningfully expand on section 893.28(2).

    In Williams, American Transmission Company (ATC), appealed a circuit court order allowing David Williams (Williams) to proceed with a claim for inverse condemnation against ATC. Williams’s property was previously owned by a railroad company that in 1969 entered into a “pole and wire agreement” with ATC to construct and maintain electrical poles and transmission lines on the railroad company’s property.

    The agreement between the two entities stated that it was revocable on 30 days’ notice. Pursuant to the agreement, ATC constructed and maintained power and transmission lines on the property.

    The railroad company sold the property in 2003 to Williams, who demanded that ATC remove the power and transmission lines from the property. Williams subsequently filed a claim for inverse condemnation against ATC, who in turn counterclaimed under section 893.28(2), asserting it had a prescriptive right to use the property.

    The court deemed the essential dispute as whether ATC’s electrical and transmission lines constituted “use of rights in real estate of another” as set forth by section 893.28(2). Williams argued that the “pole and wire agreement” was merely a license allowing the privilege for use of land, that the rights granted were explicitly revocable, and that the license was not a grant of interest in the land.

    The court assumed that Williams was correct that the agreement was no more than a license without interest in the land, but the court nevertheless found the point irrelevant, because the statute merely required continuous use and did not allow for limited exceptions – even written agreements – that could defeat the creation of a prescriptive easement.

    The Williams court laid out the distinctions in statutory language between the subsections (1) and (2) of the statute:

    We recognize that our interpretation of Wis. Stat. § 893.28(2) has the effect in some circumstances of negating the ability of a landowner to revoke a permissive use of his or her property. It would appear, however, that this is precisely what the legislature intended. The statutory language, particularly when read in the context of the entire statute, shows that § 893.28(2) applies to permissive uses. Section 893.28(2) does not specify that the “use” be non-permissive. Indeed, § 893.28(2) does not specify that the use be of any particular sort whatsoever. In contrast, the legislature included a requirement of “adverse” use in § 893.28(1), a closely related provision pertaining to prescriptive rights for non-utilities. By omitting any requirement that a use be “adverse” under § 893.28(2), the legislature indicated that the elements for “adverse” use under § 893.28(1) are not necessary for prescriptive rights under § 893.28(2).8

    The court noted that its reading of the statute was confirmed by the legislative drafting history showing that the word “adverse” was removed from the proposed statute by a senate amendment. A note accompanying the amendment stated that the change “cuts off the interest of the property owner and transfers the right to an easement to the utility after 10 years even if the use by the utility were permissive[,] e.g., if the utility had been paying rent.”

    The court went on to state that it was not persuaded that section 893.28 is titled “prescriptive rights by adverse user” because, although a statutory title might assist in resolving ambiguity in the statute, such titles cannot be used to create ambiguity in language that is otherwise unambiguous, which it found subsection (2) to be.9

    Williams argued that this reading of the statute was detrimental to public policy because it left landowners in a position where they needed to demand a utility remove equipment before the 10-year period elapses, thus causing the local residents to lose phone or electrical service, or to lose property rights. The court again found Williams’ arguments unpersuasive:

    The legislature has simply concluded that, if a utility has continuously used rights in property of another for at least 10 years, then prescribing a right to continue that use is consistent with sound public policy. The legislature has apparently determined that, even if the statute deters some property owners from granting utilities permissive use of their property, alternative options, including condemnation when available, are sufficient.

    These arguments form the current ubiquitous understanding of the statute in the Wisconsin judiciary. The plain reading of subsection (2) distinguishes itself from other statutory and common-law principles of adverse possession. A landowner can give express permission to a defined utility for the use of land, and if that permission is not revoked within 10 years, the right of that utility to continue using the prescriptive easement can continue indefinitely, within certain limitations.

    Wisconsin Supreme Court in Garza: Improvements Do Not Terminate Prescriptive Easements

    The Wisconsin Supreme Court weighed in on section 893.28(2) with its decision in
    Garza v. American Transmission Company.10

    In Garza, former owners of a property, the Hertigs, granted an easement to the Wisconsin Public Service Corporation (WPSC) by deed dated June 28, 1969. The easement, titled “Transmission Line Easement,” stated WPSC was granted:

    [T]he perpetual right, privilege and easement to erect, maintain and operate an electric transmission line, comprising wood pole structures[,] conductors[,] and other wires, counterpoises, guy wires, braces and other usual appendages and appurtenances of such kind as said Grantee, its successors and assigns, may from time to time determine, for transmitting electric current over and across [the Hertigs' property].11

    The agreement also provided that:

    Together with the right from time to time to enter upon said premises for the purpose of erecting said line, and changing, repairing, patrol[l]ing, replacing and removing the same, and the right from time to time to clear all brush and trees within 40 feet of each side of the center line of such transmission line and the right from time to time to cut down, trim or remove such trees on said premises beyond such 40 feet as in the judgment of Grantee, its successors and assigns, may interfere with or endanger said line, and to do any and all other acts necessary in the proper erection, maintenance, safeguarding, and operation of said line.

    Pursuant to the 1969 easement, WPSC constructed a transmission line with wooden poles on the described route. In 1977, the Hertigs subdivided their property to create a housing subdivision. In 1995, to meet the area’s increased electrical needs, WPSC upgraded its transmission line to allow it to carry more electricity, and replaced the wooden poles supporting the line with steel poles.

    WPSC assigned the easement to American Transmission Company (ATC) in 2001. In September 2004, the Garzas purchased a lot in the subdivision. The Garzas did not dispute that at the time of purchase, they were aware of the transmission line, received a copy of the 1969 easement, and that the easement was noted on their title insurance policy.

    The transmission line in the subdivision was not located on the Garza’s purchased lot. However, the property was located within the proximity of the 80-foot strip of land that WPSC had reserved the right to clear trees and brush from if they interfered or endangered the transmission line. ATC contacted the Garzas in late 2010 to notify them of their intention to perform trimming and tree removal on and bordering the Garza property. In its brief to the Wisconsin Supreme Court, ATC explained that these actions were necessary to ensure the safe and reliable operation of the transmission line, and cited a 2003 event in Ohio where tree damage to a transmission line caused an estimated 50 million people to lose power for two days.

    The Garzas filed an inverse condemnation action. ATC filed a declaratory judgment action seeking an order declaring its right to enter the Garza property to trim and remove trees, pursuant to the 1969 easement or by prescriptive easement under section 893.28(2). The circuit court ruled in favor of ATC, stating the unambiguous language of the easement allowed for replacing the transmission lines in perpetuity, and that WPSC “stayed within the general bounds of the easement and only furthered the use of the enjoyment when the power demands of the area necessitated changing the facility.”

    The court of appeals reversed the circuit court’s ruling, interpreting the 1969 easement as limiting the transmission line to being constructed on wooden pole structures rather than steel, and that ATC failed to show it had prescriptive easement rights to trim and remove trees on the Garza property.

    Reversing the court of appeals’ decision, the Wisconsin Supreme Court outlined the basic principles of easements, noting that any use not in accordance with the specific right to use granted in an easement is outside the easement's scope and thus prohibited.

    The Supreme Court rejected the argument that the easement specifically required wooden pole structures. Instead, the Court believed that such technological progress was reasonable and allowed by long held principles. First, the Court held the easement’s wording was not language of circumscription, but rather language of description that did not limit the transmission line to being exclusively used with wood poles. And second, easements allow for reasonable implementation of advances in technology without extinguishing the right of use.

    The Court cited the Restatement (Third) of property, which states:

    Except as limited by the terms of the servitude determined under § 4.1, the holder of an easement or profit as defined in § 1.2 is entitled to use the servient estate in a manner that is reasonably necessary for the convenient enjoyment of the servitude. The manner, frequency, and intensity of the use may change over time to take advantage of developments in technology and to accommodate normal development ofthe dominant estate or enterprise benefited by the servitude. Unless authorized by the terms of the servitude, the holder is not entitled to cause unreasonable damage to the servient estate or interfere unreasonably with its enjoyment.

    The Court concluded that the change from wood to steel poles was indeed a reasonable change because of technological advancement, and that the transmission line changes allowed necessary electric distribution system improvements to occur because the old lines were incapable of providing the electricity needed with development. Further, the language of the easement had expressly anticipated and allowed for proper maintenance, replacing, and repairing of the line.

    The Court carefully noted that the right to take advantage of technological advances was not unlimited, and that the dominant estate could not cause unreasonable damage to the servient estate or interfere unreasonably with its enjoyment.

    For the facts in Garza, the Court stated that the change from wood to steel poles placed no undue burden on the Garza estate. In fact, the use of steel poles allowed for more weight support than wooden poles, meaning less poles near the property were needed overall to support the upgraded transmission line. The poles were also constructed within the boundary of the 1969 easement, and took up no additional space.

    The holding in Garza can reasonably be read as allowing upgrades to utility infrastructure within the existing “footprint” of a prescriptive easement under section 893.28(2). Specific language from a granted easement might extend or limit the easement within reason so that both the dominant estate asserting the prescriptive easement can enjoy its use, and also that the subservient estate is not unduly burdened.

    The Garza ruling outlines how a utility could go from overhead to underground and maintain its prescriptive easement. The Garza decision outlined the non-burden of having fewer poles to transport electricity within the same spatial footprint, and more importantly, the public interest in allowing such lines to carry increased electrical capacity without risk of damage from overgrown or falling trees.

    This logic neatly applies to the conversion of overhead to underground lines. Moving electrical lines underground makes them undeniably safer for the community and wildlife. There is no risk of falling debris or storms knocking over these poles and causing power outages, and a potential eyesore is removed and nearly invisible, even allowing for the general use of the property above the lines.

    Presumably, such lines can also benefit from upgrades that safely increase the capacity of electrical current. So long as all of this takes place within approximately the same general spatial footprint as the overhead lines, it is difficult to imagine how the Garza decision would not view the upgrade as an allowable technological improvement that preserves a prescriptive easement.

    Recent Wisconsin Supreme Court Affirmation: Bauer v. Wisconsin Energy Corporation

    On Feb. 24, 2022, the Wisconsin Supreme Court handed down a decision that not only follows, but also expands on the rulings in Williams and Garza, with Bauer v. Wisconsin Energy Corporation.12

    Bauer adds considerable support for the Garza decision, and also states that the statute clearly abrogated any possible claim-of-right and adversity requirements that might apply to other adverse possession or prescriptive right cases. In other words, the Supreme Court has dispelled any notion that the courts are going to diverge from its clear precedent on this issue, absent a modification of the statute itself.

    In Bauer, the Wisconsin Energy Corporation (WEC) in July 1980 installed a single half-inch diameter plastic natural gas pipeline under the property of Virginia Garside, with her written permission that stated WEC could “cross [her] property … to put a gas line into the [neighboring home].”

    WEC periodically serviced the gas line. In 1988, WEC spliced part of the line with new pipe of the same diameter and material. The record indicated other “relocation” maintenance efforts were performed, but WEC contended that the phrase did not mean the line was moved.

    In 1996, Claudia Bauer purchased Garside’s property, but had no knowledge of the gas line under it. She learned of it in 2014 when WEC contacted her to acquire an easement to upgrade the gas line to better service the neighboring home. Bauer declined to grant the larger easement and sued WEC, as well as the neighboring property owners.

    In her appeal to the Wisconsin Supreme Court, Bauer sought a declaration that WEC lacked an easement to continue operating the gas line under her property, and she brought claims against WEC for trespass and ejectment. WEC counterclaimed for its own declaration that it obtained a prescriptive right to continue use of the gas line pursuant to section 893.28(2). The circuit court ruled in favor of WEC, and the court of appeals affirmed.

    The Supreme Court noted that section 893.28(2) diverged from the common law in three significant ways that had been touched on in the Williams decision:

    First, the statute omits any mention of the use being “adverse” or “hostile and inconsistent with the exercise of the titleholder's rights.” The parties agree the statute omits that language so as to allow permissive uses, such as licenses, to ripen into prescriptive rights. Second and also undisputed, the statutory vesting period is reduced from 20 to 10 years. Finally, § 893.28(2) contains no mention of the use being either “visible, open, and notorious” or “under an open claim of right.”13

    WEC argued that the omission of language pertaining to “visible, open, and notorious” or “under an open claim of right” within section 893.28(2) demonstrated legislative elimination of the two requirements. Bauer argued that the Legislature needed to be more unambiguous than merely being silent for those common-law requirements to be abrogated.

    The Court stated that the context of the statute clearly abrogated the claim-of-right requirement as well as an adversity requirement:

    The legislature, then, necessarily had to remove both the adversity and claim-of-right requirements to allow a permissive use to ripen into a prescriptive right. This conclusion makes sense in light of the common view that a claim of right is a subpart of the larger adversity requirement.14

    Unlike the above language in which the Court found there to be explicit directives in the statute, the Court assumed, without deciding, that section 893.28(2) still required a public utility’s use to be visible, open, and notorious. Instead, the Court explained that regardless of how they might answer the question, the conclusion in their ruling in Bauer would remain the same.

    The issue as outlined by the Court was whether WEC’s use after the permission it was granted permission in 1980 was both 1) continuous for a period of 10 years, and 2) visible, open, and notorious. The Court held both conditions were met.

    Continuous use, the Court wrote, is one that is neither voluntarily abandoned by the party claiming a prescriptive right, nor interrupted by an act of the landowner or a third-party.15

    Citing its decision in Garza, the Court further stated that a use remains continuous even when the prescriptive user takes measures reasonably necessary to maintain or improve the easement’s use, so long as those measures are not inconsistent with the use’s original nature and character, nor more burdensome to the landowner.

    The Court examined the element of visible, open, and notorious use as that which would put a reasonably diligent landowner on notice of the use. This gives a landowner the opportunity to assert his or her rights. But Bauer conceded that the previous owner of her lot had actual knowledge of WEC’s use because that person gave written permission.

    The Court noted that the nature and character of WEC’s claimed right was to provide gas service to a neighboring home via an underground plastic pipe. This use began in 1980 and apparently continued uninterrupted through 1990, at which point the use ripened into a prescriptive right.

    Bauer contended that each repair on the pipe restarted the 10-year clock to ripen into a prescriptive easement. The Court found this argument lacking, because the line had not actually been moved and the purpose of supplying gas along a single conduit had not changed. Further, these repairs did not increase the burden on the landowner, and the land rendered unbuildable by the line remained the same.

    Public Interest versus Private Property Rights: Public Interest Wins

    It took two decades from the enactment of section 893.28(2) until the issue of utility use of prescriptive easements under the statute reached the Wisconsin Court of Appeals.16 It was almost three decades before a published decision on the matter arose in Williams.

    But the Wisconsin Supreme Court’s rulings in Garza and now Bauer effectively cement Wisconsin’s judicial interpretation of the statute and precedent in a clear and meaningful way.

    That precedent holds that the Legislature sought to distinguish the normal common-law principles of adverse possession specifically as it relates to the work of utility companies. In the modern era, electrical and telecommunication provision are the backbones to work and leisure for most of the population. It is not hard to imagine the immense burden on utility companies and the public writ large if the potentially dizzying rules around other common-law or statutory applications of adverse possession and the recording of these interests consistently applied to something like electrical lines.17

    For example, a single landowner could upend for any number of trivial reasons an entire neighborhood’s infrastructure network to the detriment of thousands and at great expense for all involved.

    The Wisconsin Legislature sought to head off that potential cataclysm in property rights as a matter of law and sound public policy by deciding that individual property rights must give way to progress.

    This article was originally published on the State Bar of Wisconsin’s Litigation Section Blog. Visit the State Bar sections or the Litigation Section webpages to learn more about the benefits of section membership.


    1 See Leimert v. McCann, 79 Wis. 2d 289, 300, 255 N.W.2d 526 (1977) (citing3 Powell on Real Property, § 405, 386-387; Public Service Corp. v. Marathon County, 75 Wis. 2d 442, 446, 249 N.W.2d 543 (1977)) (quoting Schwartz v. Evangelical Deaconess Society, 46 Wis. 2d 432, 438 n.25, 175 N.W.2d (1970)).

    2 Brandt Tr. v. United States, 572 U.S. 93, 105 (2014) (citingRestatement (Third) of Property: Servitudes § 1.2(1) (1998)).

    3 Chapman v. Sheridan-Wyoming Coal Co., 338 U.S. 621, 627 (1950) (citing Trs. of Columbia Coll. v. Lynch, 70 N.Y. 440, 447 (1877)).

    4 See Wis. Stat. § 893.33.

    5 Easement, Black’s Law Dictionary Free (2nd ed.) and The Law Dictionary.

    6 See Schauer v. Baker, 2004 WI App 41, 270 Wis. 2d 714, 678 N.W.2d 258.

    7 Williams v. Am. Transmission Co., LLC, 2007 WI App 246, 306 Wis. 2d 181, 742 N.W.2d 882. Two unpublished court of appeals decisions discussing subsection (2) preceded the Williams decision: Stewart v. Vision Communs., 2000 WI App 94, 234 Wis. 2d 526, 611 N.W.2d 471, and Wis. Pub. Serv. Corp. v. Bohm, 2004 WI App 149, 275 Wis. 2d 877, 685 N.W.2d 172. Both cases briefly discussed similar legal conclusions to Williams and later cases.

    8 Id. ¶ 9 (footnote omitted).

    9 Id. ¶¶ 11-12 (citing State v. Black, 188 Wis. 2d 639, 645, 526 N.W.2d 132 (1994) (“Consideration of a statutory title may be used only to resolve doubt as to the meaning of the statute.”); Wisconsin Valley Improvement Co. v. PSC, 9 Wis. 2d 606, 618, 101 N.W.2d 798 (1960) (“[T]itles may be resorted to in order to resolve a doubt as to statutory meaning ... [but] should not be resorted to in order to create a doubt where none would otherwise exist.”); Wis. Stat. § 990.001(6) (“titles to subchapters, sections, subsections, paragraphs and subdivisions of the statutes and history notes are not part of the statutes” for purposes of statutory construction)).

    10 Garza v. Am. Transmission Co. LLC (In re Garza), 2017 WI 35, 374 Wis. 2d 555, 893 N.W.2d 1.

    11 Id. ¶ 4 (footnote omitted).

    12 Bauer v. Wis. Energy Corp., 2022 WI 11, 2022 Wis. LEXIS 12, 2022 WL 552612 (Feb. 24, 2022) (subject to further editing and modification as of April 1, 2022).

    13 Id. ¶ 19 (citations omitted).

    14 Id. ¶ 21 (citing Simmons v. Berkeley Elec. Coop., Inc., 419 S.C. 223, 232, 797 S.E.2d 387 (2016); 28A C.J.S. Easements § 43; John W. Bruce & James W. Ely, Jr., The Law of Easements & Licenses in Land § 5:8 (2021)).

    15 Id. ¶ 24 (citing Red Star Yeast & Prods. Co. v. Merch. Corp., 4 Wis. 2d 327, 335, 90 N.W.2d 777 (1958); 25 Am. Jur. 2d Easements and Licenses § 51).

    16 Supra footnote 7.

    17 See, generally, Jesse Ishikawa, “Equity, Old Facts, and Wisconsin’s Law of Easements,” Wisconsin Lawyer, July 2004.

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