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Open Records — corporations

Wisconsin Court of Appeals


Open Records — corporations

The Wisconsin Counties Association is not subject to the open records law.

“We reject the Police Association’s argument based on the decision in Beaver Dam, because it is not supported by any language in that decision. In Beaver Dam, the court held that ‘a quasi-governmental corporation is a corporation that resembles a governmental corporation,’ and applied the totality of circumstances test to determine whether the private Beaver Dam Area Development Corporation in that case was ‘quasi-governmental.’ 312 Wis. 2d 84, ¶¶3, 9, 44-45. While the court also referred to the issue as being whether an ‘entity is a quasi-governmental corporation,’ see, e.g., id., ¶¶7, 9, 45, the Police Association points to no language in that decision that indicates that the court intended to extend the reach of either its holding or WIS. STAT. § 19.32(1) to embrace entities that are not corporations. As the Counties Association notes, ‘to be a “quasi-governmental corporation,” an entity must first be a “corporation,”’ and the Counties Association is not a corporation.”


Recommended for publication in the official reports.

2014AP249 Wisconsin Professional Police Association, Inc., v. Wisconsin Counties Association

Dist. IV, Dane County, Niess, J., Kloppenburg, J.

Attorneys: For Appellant: Palek, Roger W., Madison; Palmer, James L., Madison; For Respondent: Borowski, Daniel J., Mequon; Phillips, Andrew T., Mequon; Henneger, Patrick Casey, Mequon

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