Village of Reeseville v. Frederick J. Prough, 2024AP1046, 7/3/25, District IV (ineligible for publication); case activity
In a case of potential interest to those litigating ordinance violations, COA holds that an alleged technical defect in the citation form does not void the citation itself.
While the facts of this appeal are almost entirely irrelevant to our readership, we thought those practitioners whose cases intersect with municipal ordinance violations would be interested in this issue of statutory construction. Pursuant to § 66.0113, citations issued by municipalities must conform to certain technical requirements. One of those requirements is that the citation include the “factual allegations describing the alleged violation.” (¶24). Here, however, the section of the citation form labeled “Violation Description” was left blank. (Id.). COA, however, is unconcerned by this alleged defect. Here, the citation “specifically describes” the alleged offense elsewhere on the citation. (¶25). Accordingly, COA affirms.