Nancy Kormanik v. William Brash

2022 WI 67
CourtWisconsin Supreme Court
DecidedOctober 26, 2022
Docket2022AP001736-W
StatusPublished
Cited by1 cases

This text of 2022 WI 67 (Nancy Kormanik v. William Brash) is published on Counsel Stack Legal Research, covering Wisconsin Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Nancy Kormanik v. William Brash, 2022 WI 67 (Wis. 2022).

Opinion

2022 WI 67

SUPREME COURT OF WISCONSIN NOTICE This order is subject to further editing and modification. The final version will appear in the bound volume of the official reports.

No. 2022AP1736-W

State of Wisconsin ex rel. Nancy Kormanik,

Petitioner,

v. FILED William Brash, in his official capacity as OCT 26, 2022 Chief Judge of the Court of Appeals, Sheila T. Reiff Respondent, Clerk of Supreme Court Madison, WI

Wisconsin Elections Commission, Democratic National Committee, and Rise, Inc.,

Interested Parties.

The Court entered the following order on this date:

¶1 Nancy Kormanik has filed a petition for a supervisory

writ, claiming that petitions for leave to appeal filed by the

Democratic National Committee ("DNC") and Rise, Inc. ("Rise") in

Kormanik v. Wisconsin Elections Commission, Case Nos. 2022AP1720-

LV and 2022AP1727-LV, are pending in the wrong appellate district.

Because we agree with Kormanik, we grant her petition for a No. 2022AP1736-W

supervisory writ and vacate the appellate order transferring venue

from District II to District IV.

¶2 This case arose out of a lawsuit filed by Kormanik in

Waukesha County circuit court against the Wisconsin Elections

Commission ("WEC"). Generally speaking, the complaint alleged

that two documents provided by the WEC to municipal clerks

erroneously interpreted certain election statutes as permitting a

clerk to "spoil" an absentee ballot at an elector's request. The

complaint asked the circuit court to: (1) declare that municipal

clerks are prohibited from "spoiling" a previously completed and

submitted absentee ballot; (2) declare that any WEC publication

that states otherwise shall be rescinded or otherwise removed from

availability to the public; (3) declare that the WEC failed to

promulgate the documents at issue as administrative rules; and (4)

temporarily and permanently require the WEC to cease offering

incorrect guidance and to promptly issue corrected guidance.

¶3 Rise and the DNC moved to intervene in the matter. The

circuit court granted their motions.

¶4 Kormanik moved the circuit court to issue a temporary

injunction directing the WEC to withdraw the challenged documents

and to cease providing further guidance on the subject. On Friday,

October 7, 2022, after a hearing, the circuit court granted

Kormanik's motion and thereby required the WEC to withdraw the

challenged documents and all similar publications, as well as to

2 No. 2022AP1736-W

notify all municipal clerks and local elections officials of their

withdrawal, by 7:00 p.m. on October 10, 2022. The WEC moved the

court to stay the temporary injunction, which the circuit court

denied.

¶5 Later on October 7, 2022, the DNC and Rise filed separate

petitions for leave to appeal and requests for a stay of the

circuit court's temporary injunction pending appeal. The DNC and

Rise directed their petitions and stay requests to appellate

District IV.

¶6 The court of appeals, by Chief Judge William Brash,

ordered the parties to file letter memoranda by Monday, October

10, 2022, regarding the proper appellate district to consider the

petitions and stay requests.

¶7 The letter memoranda subsequently filed by the parties

addressed the following statutes (2019-20):

Wis. Stat. § 752.21

(1) Except as provided in sub. (2), a judgment or order appealed to the court of appeals shall be heard in the court of appeals district which contains the court from which the judgment or order is appealed.

(2) A judgment or order appealed from an action venued in a county designated by the plaintiff to the action as provided under s. 801.50(3)(a) shall be heard in a court of appeals district selected by the appellant but the court of appeals district may not be the court of appeals district that contains the court from which the judgment or order is appealed.

3 No. 2022AP1736-W

Wis. Stat. § 801.50(3)(a) and (b)

(a) Except as provided in pars. (b) and (c), all actions in which the sole defendant is the state, any state board or commission, or any state officer, employee, or agent in an official capacity shall be venued in the county designated by the plaintiff unless another venue is specifically authorized by law.

(b) All actions relating to the validity or [invalidity] of a rule or guidance document shall be venued as provided in s. 227.40(1).

Wis. Stat. § 227.40(1)

(1) Except as provided in sub. (2), the exclusive means of judicial review of the validity of a rule or guidance document shall be an action for declaratory judgment as to the validity of the rule or guidance document brought in the circuit court for the county where the party asserting the invalidity of the rule or guidance document resides or has its principal place of business or, if that party is a nonresident or does not have its principal place of business in this state, in the circuit court for the county where the dispute arose. The officer or other agency whose rule or guidance document is involved shall be the party defendant. . . . The court shall render a declaratory judgment in the action only when it appears . . . that the rule or guidance document or its threatened application interferes with or impairs, or threatens to interfere with or impair, the legal rights and privileges of the plaintiff. A declaratory judgment may be rendered whether or not the plaintiff has first requested the agency to pass upon the validity of the rule or guidance document in question.

¶8 In its legal memorandum to Chief Judge Brash, the DNC

argued that according to precedent——primarily, State ex rel. DNR

v. Wisconsin Court of Appeals, District IV, 2018 WI 25, 380

Wis. 2d 354, 909 N.W.2d 114——Kormanik's complaint fell within the 4 No. 2022AP1736-W

scope of § 801.50(3)(a), and therefore triggered the appellate

venue-shifting provision of § 752.21(2). The DNC argued that

because, under DNR, a plaintiff still "designates" a circuit court

venue under § 801.50(3)(a) even though the plaintiff is required

by another statute to lay venue in that particular county, Kormanik

should also be deemed to have designated venue under

§ 801.50(3)(a)——thereby triggering the venue-shifting provision of

§ 752.21(2)——even though her complaint cited § 801.50(3)(b).

Finally, the DNC argued that Kormanik's complaint fell within the

scope of § 801.50(3)(a) because her claim goes beyond that

contemplated by § 801.50(3)(b) in that it is not restricted to a

§ 227.40(1) action relating to the validity or invalidity of a

guidance document, but additionally seeks injunctive relief.

¶9 Like the DNC, Rise argued in its letter memorandum to

Chief Judge Brash that Kormanik's complaint is governed by Wis.

Stat. § 801.50(3)(a) because her complaint was not truly a

challenge to the validity of a guidance document, but instead was

one seeking a declaratory judgment regarding various election

statutes.

¶10 In her letter response to Chief Judge Brash's order,

Kormanik argued that her case was venued as a matter of law under

Wis. Stat.

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Nancy Kormanik v. William Brash
2022 WI 67 (Wisconsin Supreme Court, 2022)

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