Wisconsin Voter Alliance v. Terry Reynolds, 1 N.W.3d 748

Wisconsin Voter Alliance (Alliance) sought guardianship records from Juneau County Register in Probate Terry Reynolds, alleging wards under guardianship were improperly registered/voting.
Alliance’s requests (June 28 and July 26, 2022) included Notice of Voter Eligibility (NVE) forms and other guardianship data dating back to 2016; Alliance later narrowed its appeal to only NVE forms.
NVE forms are completed by the register in probate, become part of the guardianship court file, and were used to notify the Wisconsin Elections Commission (WEC) of a court determination about voting capacity.
Reynolds denied the requests, citing WIS. STAT. § 54.75 (which closes court records "pertinent to the finding of incompetency") and privacy interests; Alliance filed a mandamus petition under the public records law.
The circuit court dismissed the mandamus petition with prejudice, concluding § 54.75 barred disclosure of the NVE forms and that Alliance had not shown a statutory exception or a plain legal duty to disclose; Alliance appealed and also asserted judicial bias.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether NVE forms are "court records pertinent to the finding of incompetency" under WIS. STAT. § 54.75, and thus exempt from disclosure	NVE forms were created after the competency finding and therefore are not "pertinent" to the finding; Alliance has a right to inspect under open records law	NVEs are part of the court file, contain the court's determination on voting capacity, are the statutorily prescribed means to communicate that determination, and thus are "pertinent" and closed under § 54.75	Court held NVEs are "pertinent to the finding of incompetency," barred from disclosure under § 54.75; Alliance lacks a clear legal right and Reynolds lacks a plain legal duty to disclose, so mandamus fails
Whether the circuit judge exhibited objective judicial bias requiring reversal	Court used language ("political," "fishing expedition") that shows an objective risk of bias and denial of impartial adjudication	Statements were contextual, addressed the breadth and purpose of Alliance's request, and did not evince extreme facts creating a serious risk of bias	Court held Alliance failed to rebut the presumption of impartiality; no objective bias shown and no reversible error

State ex rel. Greer v. Stahowiak, 287 Wis. 2d 795 (Ct. App. 2005) (mandamus compels public officer to perform legal duty)
Watton v. Hegerty, 311 Wis. 2d 52 (2008) (four prerequisites for mandamus to compel disclosure of records)
State ex rel. Zignego v. WEC, 396 Wis. 2d 391 (2021) (review of mandamus discretionary standard)
State v. Kalal, 271 Wis. 2d 633 (2004) (principles of statutory interpretation)
Miller v. Carroll, 392 Wis. 2d 49 (2020) (objective/subjective test for judicial bias)