Vol. 77, No. 6, June
2004
Court of Appeals Digest
This column summarizes selected published opinions of the Wisconsin
Court of Appeals. Prof. Daniel D. Blinka and Prof. Thomas J. Hammer
invite comments and questions about the digests. They can be reached at
the Marquette University Law School, 1103 W. Wisconsin Ave., Milwaukee,
WI 53233, (414) 288-7090.
by Prof. Daniel D. Blinka &
Prof. Thomas J. Hammer
Arbitration
Confirmation - Public Policy
Kadlec v. Kadlec,
2004 WI App 84 (filed 23 March 2004) (ordered published 28 April
2004)
A family partnership invested in real estate located in Iowa. When a
dispute arose, the matter was submitted to arbitration. One partner
signed an exclusive listing with a Wisconsin real estate broker to sell
the property on a 4 percent commission. The property sold for $1.2
million. One partner paid half the commission but the other partner
refused to pay the other half. The arbitrator issued a supplemental
order compelling the delinquent party to pay the remaining amount.
The court of appeals, in a decision written by Judge Cane, reversed.
The court found that the dispute over payment of the commission fell
within the contractual authority of the arbitrator to "resolve all
disputes" between the partners. Nonetheless, the court found that the
supplemental order violated "strong public policy."
Both Wisconsin and Iowa require licensure of real estate brokers. The
broker in this case was not licensed in Iowa. An "individual state's
power to regulate its real estate brokers through licensure requirements
must be preserved. To conclude otherwise would allow a licensed real
estate broker from one state to provide services in another state
notwithstanding that other state's requirements. The consequence of that
scenario is that all other states' regulations become meaningless. We
cannot endorse an arbitrator's award that implicates such a possibility.
Thus, we conclude this is a rare case where strong public policy
requires the arbitrator's order to be vacated" (¶ 14).
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Attorneys
Medical Treatment - Assignments - Joint and Several Liability
Riegleman v. Krieg,
2004 WI App 85 (filed 17 March 2004) (ordered published 28 April
2004)
In a two-day trial the court found that a law firm was liable for the
payment for "medical" treatment provided by a chiropractor. The court
found that the law firm had entered into a written contract that made it
jointly and severally liable for payment of any outstanding balance owed
the chiropractor. It also found that the chiropractor's treatment was
reasonable and necessary.
The court of appeals, in an opinion authored by Judge Anderson,
affirmed. After tersely disposing of a laches claim, the court of
appeals found that sufficient evidence supported the determination that
the chiropractor's charges were reasonable and necessary. In essence,
the trial judge found that the testimony offered by two chiropractors
was more credible than the testimony offered by an orthopedic doctor
(¶ 24). It next held "that the document at the center of this
controversy is a valid contract, which conveys an assignment. The
question of how to classify this type of document is an issue that has
not yet been fully addressed in Wisconsin. However, our research reveals
that the prevailing trend is for courts to hold that this type of
document - that is, the type containing language agreeing to protect a
medical provider's right to payment for services from any insurance
settlement - is a valid contract which creates an assignment and
entitles the medical provider (the assignee) the right of contractual
enforcement against both the patient (the assignor) and the patient's
lawyer" (¶ 25). The contract language unambiguously obliged the law
firm to protect the chiropractor's financial interests in receiving
payment for services rendered. The court of appeals discussed case law
from other states that supported this determination.
The opinion concludes with an "instruction": "If an attorney and
client have signed an assignment in favor of a medical provider and a
dispute arises over whether the amount owing is reasonable and
necessary, and if the attorney does not want to hold funds indefinitely,
he or she should bring an action for declaratory judgment pursuant to
Wis. Stat. § 806.04 and seek guidance from the court as to who is
entitled to the disputed funds. Specifically, the attorney should do the
following: 1. Commence a declaratory judgment action under Wis. Stat.
§ 806.04 naming the patient as plaintiff and the medical care
provider as defendant. 2. Deposit or file the disputed amount with the
Clerk of Courts. We note that the standard language of these assignments
authorizes payment of a yet to be determined amount of money (i.e.,
authorizes the patient's attorney to pay directly to the medical
provider 'such sums as may be due and owing'). When an amount
is yet to be determined, the trial court has the inherent authority to
determine what is reasonable and necessary" (¶ 36).
The court also offered these further words of "advice and caution to
attorneys faced with similar circumstances: An attorney should not
assume that he or she can ignore an assignment that he or she has agreed
to honor simply because a client changes his or her mind about the
assignment - to make such an assumption is contrary to rules of
professional conduct, which require that disputed funds be held in trust
'until the dispute is resolved.' SCR 20:1.15(d). When dealing with an
attorney, another person (whether an attorney or a lay person) has the
right to expect that the attorney will be honest and straightforward. If
an attorney signs a document intending that the medical provider rely
upon it to continue to render care and to postpone collection efforts,
while intending not to be obligated to dispense settlement proceeds to
the medical provider, a more serious question of misrepresentation and
fraud could arise" (¶ 37) (citation omitted).
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Consumer Law
Wisconsin Consumer Act - Standing to Bring Claim
Zehetner v. Chrysler Fin.
Co., 2004 WI App 80 (filed 30 March 2004) (ordered published 28
April 2004)
The plaintiff and her boyfriend, who is the father of the plaintiff's
child, went to an automobile show and offered to buy a car from a
dealership. They both signed a motor vehicle purchase contract that
listed both of their names as the "prospective purchaser." The boyfriend
applied for credit to finance the purchase, but his credit application
was denied. The plaintiff and her boyfriend then completed and signed a
credit application as joint applicants, the plaintiff providing
employment and credit reference information and describing her
co-applicant as her "fiancé."
Using the joint credit application, the salesperson obtained approval
from Chrysler Financial to finance the purchase. Eventually the
plaintiff and her boyfriend parted ways, and the boyfriend defaulted on
the loan. Chrysler demanded payment from the plaintiff and ultimately
named her as well as her former boyfriend as defendants in a small
claims replevin action. Although the plaintiff did not have the car and
believed that her former boyfriend was responsible for the payments, she
accepted Chrysler's representation that she was obligated to make the
payments and that her credit rating would suffer if she failed to do so.
In fact, she made several payments totaling more than $2,000.
Apparently, it was later discovered that although the plaintiff had
executed several documents in connection with the purchase, she did not
sign the retail installment contract and Chrysler Financial now concedes
that she therefore had no obligation to make payments under that
contract.
The plaintiff sued Chrysler Financial on several theories, all but
one of which were dismissed by stipulation. The remaining claim alleged
that Chrysler Financial had violated Wis. Stat. section 427.104 of the
Wisconsin Consumer Act by engaging in the conduct described above. The
circuit court concluded that the plaintiff had no standing because she
was not a customer as defined by section 421.301(17), which provides in
relevant part that "customer" means "a person other than an organization
who seeks or acquires real or personal property, services, money or
credit for personal, family or household purposes."
In a decision authored by Judge Schudson, the court of appeals held
that the plaintiff satisfied the definition of "customer," concluding
that when the plaintiff provided her credit background and signed
documents to facilitate the vehicle purchase, she was arguably seeking
both personal property and credit for "personal, family or household
purposes." Said the court, "sec. 421.301(17) addresses 'personal, family
or household purposes'; unquestionably, when a woman is engaged
to the father of her child, and when they are purchasing a car together,
they apparently are doing so for anticipated personal, family and
household purposes" (¶ 17) (emphasis in original).
Finally, the court turned to section 427.105(1), which defines the
remedies available under the Wisconsin Consumer Act. The statute
provides, in part, that a "person" injured by a violation of
this chapter may recover actual damages and the penalty provided
therein, and it does not restrict recovery to "customers."
In sum, the court held that the plaintiff was a "customer" under
section 421.301(17) and a "person" under section 427.105(1) and,
therefore, had standing to pursue her action.
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Criminal Procedure
Jury Trial - Instructing Jury on Lesser-included Offense After Jury
Deliberations Commence
State v. Thurmond,
2004 WI App 49 (filed 3 Feb. 2004) (ordered published 24 March 2004)
This case raised the issue as to whether a judge can instruct on
lesser-included offenses after the jury has begun deliberating. After
lengthy deliberations that failed to produce a verdict, the state moved
the trial court to instruct the jury on lesser-included offenses. Over
defense objection the trial court granted the motion, providing the jury
with instructions on lesser-included offenses and giving the jurors
additional verdict forms. Ultimately, the jury convicted on one of those
lesser offenses.
In a majority decision authored by Judge Curley, the court of appeals
reversed. The court was able to find little guidance in Wisconsin law on
the issue raised by this appeal and thus looked to several other
jurisdictions that have dealt with it. The defendant advanced the
position taken by those courts that have adopted a per se rule that
giving a belated lesser-included instruction is prejudicial error. The
court of appeals declined to adopt a per se rule, noting that "the
weight of state authority holds that it would not be appropriate to
adopt a per se rule which would declare the belated giving of any
[lesser-included offense] instruction to be prejudicial error" (¶
14). However, the court did adopt the position taken by the Maine
Supreme Court that a reinstruction presenting choices for
lesser-included offenses not presented in the initial instructions, if
proper at all, should be a rare event, only done in exceptional
circumstances. See State v. La Pierre, 754 A.2d 978 (Maine
2000).
The principal fear is that the stalled jury may regard the newly
furnished theory of liability as the court's recommendation that the
jury resolve its impasse by agreeing to the lesser offense. In its
summary of the practice in other jurisdictions, the court said "courts
have reversed cases when post-summation lesser-included offense
instructions were given: when it appeared likely that the jury saw the
belated instructions as a court recommendation to convict; when the
timing of the instructions makes the new instruction appear overly
significant, upsetting the orderly process of the trial and upsetting
the defendant's right to a fair trial; when the defendant's presentation
of his case is harmed; and when circumstances suggest the verdict was
driven by a stalled jury's desire to disband rather than complete a fair
assessment of the evidence" (¶ 17). In this case the appellate
court believed many of these circumstances were present and,
accordingly, reversed the defendant's convictions and remanded the case
for a new trial.
Judge Schudson filed an opinion concurring in part and dissenting in
part.
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Guardianships
Child Support in Chapter 880 Proceedings - Notice of Child Support
Claim Required
Amy Z. v. Jon T.,
2004 WI App 73 (filed 31 March 2004) (ordered published 28 April
2004)
A child's maternal aunt petitioned the probate branch of the circuit
court for permanent guardianship of the child under Wis. Stat. chapter
880. The petition recited that the child's mother was deceased and that
the father had been charged with felony physical abuse of the child. At
the hearing the court granted the petition, appointed the aunt as
guardian, and, over the father's objection, entered a child support
order.
The father appealed, arguing that the circuit court did not have
authority to issue a child support order in the context of a chapter 880
guardianship proceeding and, even if it did, neither the guardianship
petition nor the ensuing proceedings provided him with adequate notice
that child support would be addressed at the hearing.
In a decision authored by Judge Nettesheim, the court of appeals
concluded that the circuit court had the authority to address child
support in the context of a chapter 880 guardianship proceeding.
However, contrary to section 880.07(1)(e), the guardianship petition
failed to state any claim for support. In the view of the appellate
court, no reasonable person responding to the petition would anticipate
that there was a claim for support. As a matter of fact, the issue of
support was first raised as the parties were making their closing
statements to the circuit court. "Given that the matter of support was
not raised until the final moments of the hearing and was not otherwise
addressed at any earlier point in the proceedings, we hold that the
proceedings did not provide [the father] with fair and adequate notice
to address the issue. We reverse the child support order and remand for
a new hearing" (¶ 22).
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Insurance
Primary Coverage - Umbrellas
Treder v. LST Ltd.
P'ship, 2004 WI App 75 (filed 9 March 2004) (ordered published
28 April 2004)
This insurance coverage dispute arose out of an injury suffered by
the plaintiff in an apartment building owned by a partnership, "LST,"
and managed by Bieck Management. At issue was responsibility for a
"second layer of coverage" for a $2 million settlement. Another insurer,
Commercial Union, paid its limits of $1 million under a general
liability policy, but it also had issued an umbrella policy that named
both LST and Bieck as insureds. West Bend issued a policy that named
only Bieck as an insured. West Bend contended that 1) Commercial Union
also was responsible for the remaining amount, and 2) in the
alternative, the insurers should share the burden pro rata. The trial
court ruled that West Bend's policy was not on "equal footing with
Commercial Union's umbrella policy, and sharing the losses on a pro rata
basis" contravened case law (¶ 2).
The court of appeals, in a decision written by Judge Curley, affirmed
based on Oelhafen v. Tower Insurance Co., 171 Wis. 2d 532 (Ct.
App. 1992). "[B]y attempting to transform what is essentially a primary
policy into an 'umbrella' policy by pointing to the 'other insurance'
clause found in the Commercial Union policy, and coupling it with the
wording of the 'real estate property managed' endorsement found in the
West Bend policy, West Bend has ignored the reasoning behind the
Oelhafen ruling. As noted, the umbrella policy serves a
different function than primary policies - it is the last line of
defense - and that is why coverage offered in primary policies is
utilized before that found in umbrella policies. Oelhafen
requires an exhaustion of primary policies before the umbrella policy
becomes responsible for any liability. Thus, as we have noted,
Oelhafen declared that umbrella policies stand apart from
primary policies, umbrella policies serve a different function than
primary policies, and, unlike a primary insurance policy, an 'umbrella
policy specifically contemplates and, in fact, requires' underlying
insurance" (¶ 20) (citations omitted).
"The West Bend policy purchased here was intended to be a primary
policy covering the business and business property. The endorsement for
managed properties has no requirement that underlying insurance exist.
... We also observe that the 'real estate managed property' endorsement
was honored in this case because the Commercial Union general liability
policy paid its policy limit - the first $1,000,000 - before coverage
was sought from West Bend. Moreover, the phrase 'except other insurance
purchased specifically to apply in excess of this insurance' references,
by implication, additional umbrella coverage that may be purchased to
sit on top of the Commercial Union umbrella policy. Because West Bend's
policy requires no underlying coverage, it is a primary policy and does
not qualify under the exception. ... Thus, it is obligated to pay its
limits before the Commercial Union umbrella policy" (¶ 21).
Ambiguity - UIM
Gohde v. MSI Ins.
Co., 2004 WI App 69 (filed 23 March 2004) (ordered published 28
April 2004)
The Gohdes were injured in an automobile accident. The issues in this
case concern the validity of a reducing clause in their underinsured
motorist (UIM) coverage. This opinion marks the third time the court of
appeals is considering the matter, the latest remand from the supreme
court coming in light of Folkman v. Quamme, 2003 WI 116.
The court of appeals, in a decision written by Judge Peterson, held
that the policy is unambiguous when read as a whole. Nothing in the
policy's organization or structure produced "contextual ambiguity." For
example, "[t]he policy takes the insured through an orderly and logical
sequence. The declarations page and index are roadmaps at the beginning
of the policy. Nothing on the declarations page states that it is the
entire policy" (¶ 13). "A reasonable insured would review the
declarations page, and then be directed by the index to the limits of
UIM coverage. Here, the insured would find the reducing clause" (¶
14). Conceding that "the conflict between 'the most we will pay'
language and the reducing clause" could arguably create some ambiguity,
it was insufficient to disrupt the policy's otherwise clear language
(¶ 15).
Judge Hoover concurred because the holding was consistent with
Folkman, although he plainly took issue with that case.
Ambiguity - UIM
Bellile v. American Family
Mut. Ins. Co., 2004 WI App 72 (filed 23 March 2004) (ordered
published 28 April 2004)
As in Gohde III (summarized above), this case called upon
the court to determine whether a UIM reducing clause in an automobile
insurance policy was ambiguous. Applying the approach set forth in
Folkman v. Quamme, the court held that this policy - like that
in Gohde III - was sufficiently clear and the reducing clause
valid.
The court of appeals, in an opinion authored by Judge Cane, closely
examined the policy's organization and language, as required by
Folkman. Since the insured conceded that the reducing clause
conformed with Wis. Stat. section 632.32(5)(i), the only remaining issue
was whether the clause somehow became ambiguous in the context of the
entire policy. (¶ 15). Although the declarations and "quick
reference index" betrayed some shortcomings, they were nonetheless
"adequate" (¶¶ 19, 21). For example, the quick reference index
did not list the UIM coverage, but "finding the endorsement [was] not an
arduous task" (¶ 21). The definitions in the endorsement's limits
of liability section did "conflict," but created neither "ambiguity" nor
"a sufficient degree of contextual ambiguity to engender objectively
reasonable alternative meanings"(¶ 23).
Judge Hoover filed the same concurrence that appears in
Gohde III (see above).
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Mortgages
Seller's Buy-back Interest Superior to Interest Created by a
Mortgage
Daughtry v. MPC Sys.
Inc., 2004 WI App 70 (filed 18 March 2004) (ordered published
28 April 2004)
The city of La Crosse owned a historical retail building. MPC offered
to buy and extensively renovate the building; the offer resulted in a
property sales contract between MPC and the city. The contract contained
a reversion clause, giving the city the right to buy back the building
for a specified price if MPC failed to "substantially complete" the
renovation by a specific date. MPC acquired financing for the project
from LaQuinta, which agreed to provide MPC with financing for both the
purchase price and renovations in exchange for a first mortgage security
interest.
When MPC failed to complete renovations on time, the city sought to
exercise the contract clause giving it the right to buy back the
building. MPC stopped making mortgage payments and LaQuinta eventually
brought a foreclosure action against MPC and named the city as a
codefendant. The circuit court granted summary judgment in favor of the
city and against both MPC and LaQuinta. With reference to LaQuinta, the
court declared that the city's ownership interest upon buy-back was
superior to the interest created by the mortgage held by LaQuinta. The
correctness of this ruling was among the issues faced by the appellate
court in this case.
LaQuinta argued that, even if MPC breached the contract, thereby
entitling the city to buy back the building, the court should
nonetheless grant summary judgment to LaQuinta because its mortgage
agreement with MPC gave LaQuinta an interest in the property superior to
the city's right to buy back the property. LaQuinta argued that the
mortgage was a "purchase money mortgage" and, as such, took precedence
over any other claim to the property.
In a decision authored by Judge Lundsten, the court of appeals
disagreed. "The parties dispute whether the mortgage is a 'purchase
money mortgage,' but we need not resolve that dispute. We agree with the
circuit court and the city that, even if the mortgage agreement between
LaQuinta and MPC is properly characterized as a 'purchase money
mortgage,' it does not give LaQuinta an interest superior to the city's
right to buy back the property" (¶ 57). In the court's view,
LaQuinta failed to provide authority for its assertion that a purchase
money mortgage has priority over the type of reversionary interest held
by the city. Said the court, "we agree with the circuit court's
conclusion that, in the absence of a provision in the contract between
MPC and the city making the city's reversionary right subordinate to the
type of mortgage held by LaQuinta, the city's reversionary right, and
its lawful exercise of that right, extinguishes LaQuinta's interest in
the [building]" (¶ 64).
The court also rejected LaQuinta's argument that its mortgage was a
"construction lien" within the meaning of the contract specification
that the city's right to buy back the building was subject to
construction liens. "LaQuinta has not provided any support for its
argument that the term 'construction lien' encompasses an interest
created by a mortgage" (¶ 67).
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Taxation
Real Estate Transfer Fee - Transfer from Partnership to
Partnership
Turner v. Wisconsin Dep't of
Revenue, 2004 WI App 82 (filed 3 March 2004) (ordered published
28 April 2004)
James and Jean Turner are husband and wife. They were doing business
as the sole partners of EPCO until it ceased operation on Dec. 31, 1997.
On Jan. 1, 1998, the Turners began doing business as the sole partners
of EPCO of WI LLP (EPCO LLP). The next day James, as general partner of
EPCO, transferred real property from EPCO to EPCO LLP by warranty deed.
The transfer was for no consideration other than assumption of the debt
by EPCO LLP and receipt of an interest in EPCO LLP by the Turners.
The Department of Revenue assessed a transfer fee on the real estate
transaction described above. The Turners appealed the assessment to the
Wisconsin Tax Appeals Commission, which concluded that the conveyance of
real estate from EPCO to EPCO LLP was subject to the Wisconsin real
estate transfer fee and was not exempt from the fee under Wis. Stat
section 77.25(15m), which is an exemption for transfers between
partnerships and family member partners. The circuit court agreed.
In a decision authored by Judge Snyder, the court of appeals
affirmed. No transfer fee exemption for partnership-to-partnership
conveyances is available under section 77.25(15m). However, under the
statute, transfers between a partnership and a partner may be exempt if
three requirements are met. First, the conveyance must be between "a
partnership and one or more of its partners." Second, all of the
partners must be related to each other as specified in the statute.
Finally, the transfer must be "for no consideration other than the
assumption of debt or an interest in the partnership."
In the opinion of the court, the conveyance at issue failed the very
first of these three prongs inasmuch as EPCO LLP was never an EPCO
partner. The Tax Appeals Commission had concluded that "there is no
family member exemption where the transfer is between partnerships
rather than from a partnership to exempted family members" (¶ 12).
The court of appeals agreed with this conclusion. For the exemption to
apply, the partner or partners who are involved in the conveyance must
be human beings, not just legal entities. Said the court, "the transfer
fee exemption available for conveyances between partnerships and family
member partners is inapplicable [in this case] because the conveyance
was partnership-to-partnership rather than partnership-to-partner"
(¶ 14).
The Turners' attempt to invoke the husband and wife exemption under
section 77.25(8m) failed because it was not raised before the Tax
Appeals Commission.
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Torts
Safe Place Statutes - Land Owners
Binsfield v.
Conrad, 2004 WI App 77 (filed 23 March 2004) (ordered published
28 April 2004)
The plaintiff was electrocuted and severely injured while working on
an outdoor advertising sign. Expert analysis revealed the existence of
more than a dozen structural problems with the sign and numerous OSHA
violations. A suit was filed against the land owner (Conrad) and the
sign owner. The trial court granted summary judgment in favor of the
land owner.
The court of appeals, in a decision written by Judge Hoover,
affirmed. The court held that the land was not a "place of employment"
within the meaning of the safe place statute because the sign was
distinct from the land on which it sat. "The safe place statute
contemplates that both the 'place' and appurtenant premises will be
subject to ownership, control, or custody of the same employer or owner"
(¶ 13). "[A]n owner of appurtenant land who does not also have
ownership, custody, or control of the 'place' cannot be liable for
injuries sustained at the 'place.' There is no dispute that Conrad
exercised no ownership, custody, or control over [the] sign" (¶
14). "Imposing safe place liability on the owner of appurtenant premises
simply because of the physical proximity would effectively make that
owner an insurer for the 'place,' a duty the safe place statute never
intended to create. For the owner of appurtenant premises to be liable,
the injury would have to occur on the premises themselves" (¶ 15)
(citation omitted).
The trial court also appropriately exercised its discretion when it
denied the plaintiff's motion for a default judgment. The basis for the
motion was that the land owner's answer was filed four days beyond the
courtesy extension allowed by the plaintiff. The record supported the
finding of "excusable neglect" (¶ 30).
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Warranties
Magnuson-Moss Warranty Act - Lessees as "Consumers" Under the Act
Peterson v. Volkswagen of
Am. Inc., 2004 WI App
76 (filed 31 March 2004) (ordered published 28 April 2004)
A bank purchased a Volkswagen (VW) Beetle from an authorized VW
dealership in order to facilitate the lease of the vehicle to the
plaintiff. In consideration for the sale of the car, VW issued and
supplied to the bank its written warranty. The plaintiff then leased and
took possession of the vehicle from the bank and the bank assigned its
rights in the vehicle warranty to the plaintiff.
Following numerous failed attempts to remedy defects in the car, the
plaintiff revoked acceptance of the vehicle in writing, which VW
refused. The plaintiff then filed a claim for breach of warranty
pursuant to the Magnuson-Moss Warranty Act, 15 U.S.C. sections
2301-2312. The circuit court dismissed the claim on a motion to dismiss,
concluding that because the plaintiff leased, rather than purchased, the
vehicle under the warranty, she failed to satisfy the Act's definition
of a "consumer" and is therefore not entitled to the Act's
protections.
In a majority decision authored by Judge Brown, the court of appeals
reversed. The sole issue on appeal was whether the plaintiff had
standing to pursue her claim under the Act, which allows a "consumer" to
bring suit when he or she claims to be "damaged by the failure of a
supplier, warrantor, or service contractor to comply with any obligation
under the [Act] or under a written warranty, implied warranty, or
service contract." Recognizing that no Wisconsin court has addressed the
question of whether an automobile lessee is entitled to enforce a
written warranty issued as part of a lease transaction under the Act and
that other jurisdictions are divided on the question, the majority
concluded that "where the sale of a vehicle is merely to facilitate a
lease, the issuance of the warranty accompanies this sale, and the
lessor explicitly transfers its rights in the warranty to the lessee -
the lessee is protected by the Magnuson-Moss Act" (¶ 15).
Judge Snyder filed a dissenting opinion.
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Wisconsin Lawyer