Judgment creditors in Wisconsin have the right to a supplemental examination of their judgment debtors to obtain information regarding their collectable assets.  This examination may require the debtors to produce records for inspection by the creditor.

In Crown Castle USA, Inc. v. Orion Logistics, LLC, 2009AP3029 (December 7, 2010), an opinion recommended for publication, the Court of Appeals determined that circuits had the authority to require companies related to a judgment debtor to produce records through the supplemental examination process set forth in Chapter 816 of the Wisconsin Statutes.  The claim was made that the judgment debtor in that case may have made fraudulent transfers to a company having common ownership to avoid collection of the judgment.

This ruling provides judgment creditors with a potential source of recovery where judgment debtors are uncollectable, if there is reason to believe that the owners of the debtor have used a commonly owned company to "hide" funds which would otherwise be available for collection.