In July 2025, the Wisconsin Supreme Court issued a decision in Evers v. Marklein (hereinafter Evers II), the second in a pair of cases fundamentally altering the Wisconsin Legislature’s veto power over the executive branch. Before Evers II, the Joint Committee for Review of Administrative Rules (JCRAR) could suspend or object to rules at any point — before or after promulgation — for nearly any reason, so long as it could tie the action to the required statutory grounds for doing so.

Ultimately, in Evers II, the court adopted the U.S. Supreme Court’s holding in Immigration & Naturalization Service v. Chadha whole cloth, concluding that the JCRAR’s suspension and objection powers constituted a legislative veto and violated the Wisconsin Constitution’s bicameralism and presentment requirements.

Overview of Evers II

Evers II, decided July 8, 2025, arose out of two rules promulgated by the Wisconsin Department of Safety and Professional Services (DSPS) that the JCRAR subsequently blocked. The first rule classified conversion therapy as “unprofessional conduct.” The second rule updated the Wisconsin Commercial Building Code.^[1] The DSPS’s conversion therapy rule was held in limbo for nearly three years after the JCRAR suspended it both pre- and post-promulgation, then objected to it indefinitely.^[2]

The court’s discussion of the case opened with a succinct explanation of the statutory requirements for rulemaking. It is worth defining some of the contours of rulemaking, even at the risk of oversimplifying this complex and laborious process. When an agency wishes to promulgate a rule, it must first draft a scope statement for the governor to approve.^[3] This statement requires, in part, (1) descriptions of existing agency policy, (2) statutory authority, (3) a description of affected stakeholders, and (4) time estimates for developing the rule.^[4] After the governor approves the scope statement, the agency must draft an economic impact statement to package with the rule and send to the legislative council, which acts as a drafting clearinghouse, for review.^[5] Unless the rule fits into a narrow set of exceptions, agencies are required to hold a public hearing and consider public comments.^[6] Once the comment period closes and the rule is drafted, agencies must submit the rule to the governor for approval and signature.^[7]

Layered on top of this process is the JCRAR’s power to approve or disapprove of rules, a power that has grown consistently since 1966.^[8] This mechanism was originally limited to a single suspension, which then had to be ratified by legislation.^[9] Over time, the JCRAR’s independent power grew, and by 2017 it could suspend rules multiple times without intervention by the full legislature and could lodge indefinite objections that lasted in perpetuity unless the legislature passed an overruling law.^[10] In addition to pre-promulgation powers, by 2024, all rules were subject to a 60-day review period during which the rule could not be promulgated while the JCRAR decided whether to suspend or object to it.^[11] All suspensions and objections required a majority vote of a quorum of the committee: “[t]his means that as few as four members of JCRAR—three percent of the legislature—may halt a rule from having effect either via an objection or suspension.”^[12]

Parties’ Arguments in Evers II

The pre-promulgation pause, the objection power, and the suspension power were all on the chopping block in Evers II.^[13] The petitioner, the governor, argued that the JCRAR’s suspension and objection powers circumvent bicameralism and presentment, the constitutional requirement that legislation be presented in a bill that passes through both houses and is ultimately signed into law by the governor.^[14] The governor argued that the court should depart from precedent, adopt the standard created by Chadha, and conclude that the JCRAR’s authority under “these statutes alter[ed] the legal rights and duties of others” and required bicameralism and presentment.^[15]

The respondents — three senators, three representatives, and the Wisconsin Legislature (hereinafter, collectively, the legislature) — argued that the suspension powers did not violate bicameralism and presentment under Wisconsin Supreme Court precedent, specifically Martinez v. Department of Industry, Labor & Human Relations and Service Employees International Union, Local 1 v. Vos (hereinafter SEIU), which together allowed the legislature to suspend promulgated rules multiple times without bicameralism and presentment. The suspension was valid in those cases because the court concluded that rulemaking is not traditional legislation.^[16] It follows that if it is permissible to block promulgated rules, which have the force of law, then it is also permissible to object to rules before promulgation.^[17] Both arguments addressed Chadha, and ultimately the court elected to follow Chadha’s holding (discussed below).

Facts and Holding in Chadha

After Chadha’s student visa expired and he remained in the United States, he received a deportation order from the Immigration and Naturalization Service (INS) and sought to have it suspended.^[18] An immigration judge held a hearing and ordered suspension of the deportation order. The suspension was then reported to Congress, and the House of Representatives passed a resolution vetoing the suspension without a recorded vote and without submitting it to the Senate or the president, a step permitted by federal law.^[19] Chadha filed for review before the U.S. Court of Appeals for the Ninth Circuit and argued that the statute allowing for the legislative veto was unconstitutional.^[20] The Ninth Circuit ruled that the provision in question violated separation of powers and directed the U.S. attorney general to cease taking steps to deport Chadha.^[21]

The U.S. Supreme Court took up the case and affirmed the Ninth Circuit’s ruling. The Court concluded that the resolution mechanism amounted to a legislative veto and was unconstitutional under Article 1, Section 1 (bicameralism) and Article I, Section 7, Clauses 2 and 3 (presentment), which divide Congress into two houses and require passage of bills by both houses and final approval by the executive.^[22] The Court concluded that the key to determining whether bicameralism and presentment are required turns upon whether actions taken “contain matter which is properly to be regarded as legislative in its character and effect.”^[23] The Court decided that the legislature’s power in this case was legislative in nature because it “had the purpose and effect of altering the legal rights, duties, and relations of persons, including the attorney general, executive branch officials, and Chadha, all outside the legislative branch.”^[24]

Justice White dissented and argued that the Court should have narrowly decided the case based on separation-of-powers principles, leaving the veto question open for full review in the context of other statutes with the mechanism in place.^[25] Justice White regarded the legislative veto as an essential mechanism for ensuring accountability from executive and independent agencies.^[26] He pointed out that over the span of 50 years, more than 200 statutes contained some form of legislative veto, and post-Chadha, Congress would be left to either narrowly and painfully circumscribe new laws or leave the door wide open to unaccountable administrative agencies.^[27] He characterized the veto power not as the ability to make law without bicameralism and presentment, but rather as the power to negate the actions of the executive branch or an agency.^[28] In his opinion, the legislative veto “no more allows one House of Congress to make law than does the presidential veto confer such power upon the President.”^[29]

Evers II Majority Holding

Justice Karofsky drafted the majority opinion, which Justice Walsh Bradley, Justice Dallet, and Justice Protasiewicz joined. The majority quoted key language directly from Chadha and concluded that, “[t]he requirements of bicameralism and presentment are triggered when legislative action alters the legal rights and duties of others outside the legislative branch.”^[30] The court reasoned that the same principles governing the federal constitution also apply to the Wisconsin Constitution and found it significant that there is a “finely wrought and exhaustively considered procedure” for the “legislative branch’s use of power.”^[31] Applying this new standard, the court held that all five statutes at issue were unconstitutional and overruled both Martinez and SEIU.

The court overruled Martinez on the grounds that it was “unsound in principle” because it misapplied the Wisconsin Constitution.^[32] The Martinez court did not address why a temporary suspension of bicameralism and presentment was permissible, and it determined that procedural safeguards were in place, “when we should have treated constitutional adherence itself as the principle procedural safeguard.”^[33] SEIU was unconstitutional because it compounded the Martinez error. Both cases “departed from our constitutional text, which provides no exception to the bicameralism and presentment requirements when a legislative action alters the legal rights and duties of others.”^[34]

The court concluded that the automatic 60-day pre-promulgation pause allowed the JCRAR to wrest control of rulemaking from agencies during that period. Even though it was limited in time, “the constitution does not contemplate temporary violations of its provisions.”^[35] The statutes allowing the JCRAR to object to a proposed rule, either temporarily or indefinitely, prevented the DSPS from completing its statutory obligations.^[36] Finally, the statutes allowing post-promulgation suspension altered the rights and duties of those outside the legislature because they effectively rescinded rules that were already in effect.^[37]

Justice Hagedorn’s Partial Concurrence & Dissent

Like Justice White in Chadha, Justice Hagedorn wrote that he would have decided the case narrowly, relying on existing precedent, and would save the deeper questions about the nature of rulemaking power for another day, in another case that had progressed through the court system.^[38] He described what the governor was asking for as “nothing less than a constitutional revolution” and said that both parties lodged deficient arguments that led to a deficient majority opinion.^[39] The governor “skips right by the hard stuff,” hoping to avoid the deeper questions about the nature of rulemaking.^[40] The legislature, on the other hand, made no attempt to argue that the ability to object to or suspend rules was consistent with the original meaning of the constitution in the first place and instead hung its hat on Martinez.^[41]

According to Justice Hagedorn, the majority adopted the governor’s arguments without interpreting the constitution and instead relied on the Chadha test.^[42] He pointed out that administrative rules are not statutory law and instead “are downstream from statutes—subject to them and promulgated pursuant to their direction.”^[43] He argued that the majority’s reasoning contradicted itself^[44] because the court concluded that pre-promulgation pauses were unconstitutional, as they affected the rights and duties of the executive branch officials responsible for enforcing laws requiring rulemaking, which only makes sense if rulemaking is an executive power.^[45] The majority then went on to decide that post-promulgation pauses are unconstitutional because they affect the rights and duties of those subject to the rule, which only makes sense if pausing a rule is a legislative act.^[46] In Justice Hagedorn’s view, the majority’s approach allows the executive branch to alter legal rights and duties of those outside the lawmaking process while prohibiting the legislature from doing so.^[47]

Justice Hagedorn found the JCRAR’s objection and the suspensions of the DSPS’s ethical rule update moot because the rule was in effect and no longer suspended.^[48] This would have dispensed of everything aside from the JCRAR’s power of indefinite objection. He would have then held that the power to indefinitely object violates the constitution under Martinez because it did not contain the same checks and balances that accompany temporary suspensions — to the Martinez court, it was essential that the permanent suspension power required “the full involvement of both houses of the legislature and the governor.”^[49]

Justice Grassl Bradley’s Dissent

Justice Grassl Bradley described the majority’s holding as an attempt to take the power away from the people, give it to the executive branch, and “empower[] unelected bureaucrats to rule over the People.”^[50] She argued that the executive branch can now make law without any checks to speak of and that the Wisconsin Constitution allows only the legislature to make laws and has never allowed for transfer of that power to another branch.^[51] Justice Grassl Bradley discussed nondelegation principles and asserted that the framers recognized that the people authorized only the legislature to bind them under law and that the original understanding of the Wisconsin Constitution prohibits the branches from subdelegating their various powers.^[52]

Like Justice Hagedorn, Justice Grassl Bradley took issue with the majority’s constitutional analysis. She characterized the majority’s action as an attempt to “strangle” the legislature while “unleashing unconstrained executive rule….”^[53] In her view, the legislature was attempting to create a check against the power that it unconstitutionally gave to the executive branch.^[54] She said that the majority failed to explain how legislative power can be constitutionally delegated, but the conditions can somehow be unconstitutional.

Justice Grassl Bradley described lawmaking as “the power to adopt generally applicable rules of conduct governing future actions by private persons—the power to ‘prescribe the rules by which the duties and rights of every citizen are to be regulated,’ or the power to ‘prescribe general rules for the government of society.’”^[55] This definition was further reinforced by the Wisconsin Supreme Court’s 100 years of precedent holding that the power to promulgate rules is inherently legislative.^[56] In her view, if the legislature is going to continue to unconstitutionally delegate power to administrative agencies, it must have the ability to check that delegation to ensure that unelected bureaucrats do not run roughshod over the rights of the people.^[57]

Chadha in Cases from Other Jurisdictions

The Evers II dissents rested on a central complaint: The majority neither addressed the Wisconsin Constitution nor considered whether rulemaking is a legislative or executive power. The majority cited several cases in other jurisdictions in a footnote for persuasive support because other jurisdictions have also required bicameralism and presentment for a legislature to block an administrative rule. These cases are analogous in that they reached similar results; however, none relied exclusively on Chadha in their holdings.

The New Jersey Supreme Court considered a law that required every administrative rule to be submitted to the state legislature, which could then refer it to standing committees. The standing committees then had 60 days to adopt a resolution disapproving the rule or delaying it from taking effect for an additional 60 days, with the option of a subsequent resolution to block the rule.^[58] The New Jersey Supreme Court did not opine on the nature of legislative power and took a functionalist approach to the sharing of powers. It still decided that the veto violated separation-of-powers principles while noting that the court did “not foreclose every legislative veto provision.”^[59] The court equated the veto power to a policy decision “equivalent to amending or repealing existing legislation,” a proposition established in New Jersey case law.^[60] The court generally referenced Chadha but did not opine on the nature of legislative power or adopt Chadha’s holding.^[61]

The Supreme Court of Appeals of West Virginia considered a legislative-veto mechanism executed by a small committee using a framework similar to Wisconsin’s invalidated laws.^[62] The court concluded that the West Virginia Constitution’s separation-of-powers section was “part of the fundamental law of [the] State and, as such, it must be strictly construed and closely followed.”^[63] It held the legislative veto at issue unconstitutional, reasoning that once the rulemaking power has been delegated, it vests in the executive, who has a “mandatory duty to promulgate and to enforce rules and regulations.”^[64] The court cited an Alaska Supreme Court case for the proposition that once a legislature takes an action with a “binding effect on those outside the legislature it may do so only by following the enactment procedures.”^[65] This is as close as the West Virginia court came to making any reference to Chadha’s analysis or holding.

Finally, the West Virginia court cited a Missouri Supreme Court case, Missouri Coalition for Environment v. Joint Committee on Rules. This case made no citations to Chadha or its language, other than a reference to a law review article examining Chadha.^[66] The Missouri court decided that “preemptive action of the legislature … must be a ‘legislative’ action. For if such action is not legislative, the legislature has no right to do it.”^[67] Missouri courts have concluded that rule promulgation is an executive function based on text in the Missouri Constitution that “expressly recognizes the authority of the executive branch to issue regulations,” with no mention of the legislature’s involvement in rule promulgation.^[68]

None of these cases required state courts to overrule precedent or provide a new definition of legislative power.

The statutes allowing the JCRAR to object to a proposed rule, either temporarily or indefinitely, prevented the DSPS from completing its statutory obligations.

Legislative Power in Wisconsin in the Wake of Evers II

Although no other state appears to have adopted the holding and test for legislative power from Chadha, 20 state courts have held that legislative vetoes are impermissible on a variety of grounds and specifically discussed Chadha.^[69] Wisconsin was an outlier in having a suspension mechanism that could be “extended indefinitely” by statute.^[70] As noted above, the JCRAR had the ability to intervene at any time, before or after promulgation, for almost any reason, provided it could find support within the required grounds for suspension or objection. Arrangements like these in other states, while constitutionally dubious, did not require overruling existing precedent or redefining the nature of legislative power, and the cases were generally decided on narrower grounds.

The frustration Justice Hagedorn and Justice Grassl Bradley expressed is not unfounded. However, whether 10 members of a legislative committee reflect the will of the populace is a lingering question. A vote of as few as four members of the committee was enough to suspend or object to a rule, less than three percent of the entire legislature. It is difficult to see how this sole committee was the bulwark against a tyrannical administrative state. Criticism on these grounds would be far more compelling had administrative rules been subject to review by the full legislature, not a microcosm of it. Still, the dissenters identified valid criticisms. The majority did not explain how the Wisconsin Constitution curbs the legislative veto and adopted Chadha’s reasoning, which was factually and procedurally distinct.

At the federal level, the legislative veto was constitutionally dubious from the start. Before the mechanism even existed, President Hoover’s attorney general opined on the possibility of such a veto and advised that it was unconstitutional.^[71] President Franklin Roosevelt signed the Lend-Lease Act, which allowed for a concurrent Congressional resolution to remove authority delegated to the president to provide defense to allied nations during World War II, even though he thought it was unconstitutional.^[72] Over time, the legislative veto became more prevalent and was embedded in numerous laws.

Chadha was met with a wave of panic and was described by some as a “shattering blow to legislative power.”^[73] In 1984, then-Senator Joe Biden was asked to opine on the disaster that some people believed Chadha was sure to cause.^[74] Over five weeks, Congress held nine days of hearings, formed task forces, and considered numerous bills.^[75] After hearing testimony, Biden concluded that “there would be no radical shift in the balance of legislative and executive power.”^[76] This is not to say that he thought the decision was without its hazards, especially as it related to foreign policy, but he was confident that Congress was equipped to restore the pre-Chadha balance.

The chaos that the dissent in Evers II predicted did not necessarily occur at the federal level in the wake of Chadha. Conventional wisdom suggests that Chadha allowed for abuse by the executive branch by removing an essential check on legislative power.^[77] But the post-Chadha world is not so clear-cut. Some legal scholars suggest that even though the veto function often was added to legislation before Chadha, it was rarely used, and even after the decision, the legislature was able to curb the executive’s power, add report-and-wait provisions, and use more informal mechanisms for maintaining control.^[78]

Even after Evers II, administrative agencies are still required to follow the detailed and exacting requirements of the rest of Wis. Stat. chapter 227. And, as the majority in Evers II stated, the legislature is free to pass any law it pleases to restrict the power of administrative agencies, as long as it does not employ a veto mechanism. As in other states, Wisconsin lawmakers have introduced a constitutional amendment to enshrine the veto power within the Wisconsin Constitution, along with bills limiting the duration of administrative rules.

In reaction to Evers II, the legislature created the 2025 Assembly Speaker’s Task Force on Rulemaking. Due in part to this task force, the legislature introduced at least five bills (all of which have been vetoed) and one constitutional amendment. Three of the bills would have fundamentally curbed executive agency rulemaking. For example, 2025 Assembly Bill 955 would have amended portions of Wis. Stat. chapter 227 and prohibited agency rulemaking without “explicit and specific” authority.^[79] 2025 Senate Bill 289 would have prohibited agency rulemaking with more than $10 million in “implementation and compliance costs” to businesses and local governments, unless a separate bill in the legislature authorized it or another rule offsetting the cost.^[80] 2025 Senate Bill 277 would have put a seven-year sundown clause into every chapter of the Wisconsin Administrative Code.^[81]

Senate Bill 277 would have imposed significant financial and temporal burdens on agencies and the legislature. Under the bill, the JCRAR would have one year to establish a schedule for the expiration of all existing administrative rules, with expirations beginning as early as 2028. If an agency did not want a rule to expire, it could submit a notice of readoption. The agency would have to submit this notice between January 1 and March 1 of the year before the expiration date. After submission, the standing committees and the JCRAR would have 40 days to object. If no member objected, the rule would be readopted. If even one member objected, the agency would have to engage in the full rulemaking process and promulgate a rule readopting the chapter. This would require state agencies and the legislature to allocate full-time staff to continually review a rolling schedule of rules in danger of expiring every single year. The Department of Transportation (DOT) alone has over 140 administrative rules (that is, chapters in the Wisconsin Administrative Code) in place, so the DOT would have to review an average of 20 rules per year, in perpetuity, not including any amendments or creation of new administrative rules.

Other portions of Wis. Stat. chapter 227 have been challenged in circuit court. Evers v. Wisconsin Legislature Joint Committee on Legislative Organization (Evers III) was filed in Dane County Circuit Court in September 2025 after various agencies submitted rules to the legislative clearinghouse without first sending them to standing committees for review.^[82] The legislative committee issued a memo stating that it was refusing to publish rules that had not gone through the standing committee process.^[83] The governor brought suit, arguing that other provisions of Wis. Stat. chapter 227 are also unconstitutional because they provide a mechanism similar to the mandatory 60-day pause at issue in Evers II. The circuit court determined that after Evers II, Wis. Stat. chapter 227 does not require administrative agencies to wait to promulgate a rule until after the standing committee review process.^[84] This case is currently before the Wisconsin Court of Appeals and will likely proceed to the Wisconsin Supreme Court regardless of the outcome at this stage.

While the full impact of Evers II is unclear, attorneys in every regulated field should be aware that dramatic legislative developments may occur. Governmental attorneys who participate in administrative rulemaking should anticipate significant changes when a new governor takes office in January 2027, especially if one party controls all three branches of Wisconsin government. Attorneys representing interests in highly regulated fields should stay abreast of legislative developments that could significantly affect their fields and their clients’ business practices.

Conclusion

Questions remain. How will Evers II be interpreted in other contexts? What will be the repercussions of Wisconsin’s new definition of legislative power? The shadow of this new definition looms large, and only time will tell how far it is cast.

Evers II may signal a sea change in how administrative rules are promulgated, forcing courts to grapple with a new conception of legislative power. Whether that shift will occur is anyone’s guess, but as then-Senator Biden wrote, “The real danger is that Congress and the executive branch will believe what they read in the press and turn the current mood of accommodation on the Chadha decision into confrontation.”^[85] What is needed most of all now is a mood of accommodation between the Wisconsin Legislature and the state’s executive branch.

Endnotes

[1] Evers v. Marklein, 2025 WI 36, ¶ 16, 417 Wis. 2d 453, 22 N.W.3d 789. Hereinafter, this case is referred to as Evers II. ^

[2] Id. ¶¶ 16–19. ^

[3] Wis. Stat. § 227.135. ^

[4] Id. ^

[5] Wis. Stat. § 227.15. ^

[6] Wis. Stat. §§ 227.16–.18. ^

[7] Wis. Stat. § 227.185. ^

[8] Evers II, 2025 WI 36, ¶ 6, 417 Wis. 2d 453. ^

[9] Id. ^

[10] Id. ¶ 8. ^

[11] Id. ¶ 9. ^

[12] Id. ^

[13] Id. ¶ 10. ^

[14] Id. ¶ 27. ^

[15] Id. ¶ 29. ^

[16] Id. ¶¶ 30–31. ^

[17] Id. ¶ 31. ^

[18] Immigration & Naturalization Serv. v. Chadha, 462 U.S. 919 (1983). ^

[19] Id. ^

[20] Id. at 919, 927. ^

[21] Id. ^

[22] Id. at 945–46. ^

[23] Id. at 952. ^

[24] Id. ^

[25] Id. at 967. ^

[26] Id. ^

[27] Id. ^

[28] Id. at 980. ^

[29] Id. ^

[30] Evers II, 2025 WI 36, ¶ 30, 417 Wis. 2d 453. ^

[31] Id. ¶ 35. ^

[32] Id. ¶ 37. ^

[33] Id. ^

[34] Id. ¶ 38. ^

[35] Id. ¶ 41. ^

[36] Id. ¶ 42. ^

[37] Id. ¶ 43. ^

[38] Id. ¶ 46. ^

[39] Id. ¶¶ 48–52. ^

[40] Id. ¶ 50. ^

[41] Id. ¶ 51. ^

[42] Id. ¶ 52. ^

[43] Id. ¶ 53. ^

[44] Id. ¶ 54. ^

[45] Id. ^

[46] Id. ^

[47] Id. ¶ 55. ^

[48] Id. ¶ 59. ^

[49] Id. ¶ 61. ^

[50] Id. ¶ 77. ^

[51] Id. ¶¶ 77–78. ^

[52] Id. ¶ 79. ^

[53] Id. ¶ 81. ^

[54] Id. ¶ 85. ^

[55] Id. ¶ 91 (citing Evers v. Marklein (Evers I), 2024 WI 31, ¶ 51, 412 Wis. 2d 525, 8 N.W.3d 395 (Grassl Bradley, J., concurring) (quoting Gundy v. United States, 588 U.S. 128, 153 (2019) (Gorsuch J., dissenting)) (citations omitted). ^

[56] Id. ¶ 92. ^

[57] See id. ¶¶ 98–101. ^

[58] General Assemb. of State of N.J. v. Byrne, 90 N.J. 376 (1982). ^

[59] Id. at 385–89, 395. ^

[60] Id. at 388–89. ^

[61] See id. ^

[62] State ex rel. Barker v. Manchin, 167 W.Va. 155 (1981). ^

[63] Id. at 167. ^

[64] Id. at 169. ^

[65] Id. at 173–74. ^

[66] Missouri Coal. for the Env’t v. Joint Comm. on Administrative Rules, 948 S.W.2d 125 (1997). ^

[67] Id. at 134. ^

[68] Id. at 133. ^

[69] Miriam Seifter, State Legislative Vetoes and State Constitutionalism, 99 N.Y.U. L. Rev. 2017, 2033–34 (2024). ^

[70] Id. at 2031. ^

[71] Curtis A. Bradley, Reassessing the Legislative Veto: The Statutory President, Foreign Affairs, and Congressional Workarounds, 13 J. Legal Analysis 439, 444-45 (2021). ^

[72] Id. at 444. ^

[73] Joseph R. Biden Jr., Who Needs the Legislative Veto?, 35 Syracuse L. Rev. 685 (1984). ^

[74] Id. ^

[75] Id. at 687. ^

[76] Id. ^

[77] Bradley, supra note 71, at 451. ^

[78] Id. at 458–59. ^

[79] 2025 Assembly Bill 955. ^

[80] 2025 Senate Bill 289. ^

[81] 2025 Senate Bill 277. ^

[82] Evers v. Wisconsin Legislature Joint Comm. on Leg. Org. (Evers III), No. 2025CV0002975, https://content.govdelivery.com/attachments/WIGOV/2025/09/12/file_attachments/3386453/Gov.%20Evers_Evers%20III%20complaint.pdf. ^

[83] Id. at 35. ^

[84] Evers v. Wisconsin Legislature Joint Comm. on Leg. Org., Brief of Appellant (Defendants), 2026AP001109. ^

[85] Biden, supra note 73, at 687. ^