How does a Wisconsin landlord lawfully end a tenancy, and when may a tenant leave early?

The landlord and tenant chapter applies to residential tenancies across Wisconsin, with no city or county variation and no lease-date cutoff. One group falls outside it entirely: occupants and guests of a campground or camping resort licensed by the state have no rights under the chapter at all, so none of the notice, abuse-termination, death or holdover rules on this page reaches them. The chapter expressly preserves the rights of people living in a manufactured and mobile home community and of people who signed a campground contract.

What decides it is the property, not the person and not the date the lease was signed: where the site is a campground or camping resort licensed under the state's recreational-establishment licensing statute, the occupant and the occupant's guests sit outside the chapter. The exclusion was created by 2025 Wisconsin Act 29 and took effect on August 10, 2025; before that date the chapter's rules reached campgrounds like anywhere else.

The switch changes: every answer on this page.

Landlord: 28 days. Tenant: 28 days.

Two things must both be satisfied, and that is what makes Wisconsin's period longer in practice than the figure. The notice must give at least 28 days, counted forward from the day it counts as given, and the tenancy can end only at the end of a rental period, so the termination date is pushed out to the next period boundary. A notice given on the tenth of a month, for a tenancy whose rental period ends on the last day of the month, therefore ends the tenancy at the end of the following month rather than 28 days later. For a year-to-year tenancy the rental period is the rental year, even where rent is paid monthly. The day the notice counts as given is day one of the period, and section 704.19, subsection (7) fixes that day for each delivery method.

The termination date must fall on a rental-period boundary or a rent-due date.

Tiers: One period covers monthly tenancies: at least 28 days. Where rent is payable on a basis less than monthly, notice at least equal to the rent-paying period is enough, so a weekly tenancy takes one week. Agricultural tenancies from year to year, which are not residential, take at least 90 days; a residential year-to-year tenancy takes the ordinary 28 days but can still end only at the end of the rental year.

A different agreed period is honored only on a heightened evidentiary showing. The chapter has no clause voiding a lease term that shortens the 28 days, and the list of provisions that make a residential agreement void does not reach the notice period. The one route around the statute runs both ways: the landlord and the tenant may agree expressly on another method of termination, but the agreement counts only if it is established by clear and convincing proof, a standard well above the ordinary civil burden. A clause invalidating contrary termination provisions except in leases longer than a year does exist in Wisconsin law, but it belongs to the for-cause notice section and is covered on the eviction page.

A statute requires the landlord's and tenant's periods to be equal, or bars a lease from imposing a longer period on one side.

Source of the period: a termination-notice statute states it.

Either the landlord or the tenant ends a month-to-month tenancy, any other periodic tenancy, or a tenancy at will by written notice of at least 28 days, and one sentence governs both sides, so neither party owes more notice than the other (section 704.19, subsections (2) and (3)). The notice may be formal or informal but must be in writing and must substantially inform the other party of the intent to end the tenancy and of the termination date. Errors that do not mislead, including leaving out the name of one of several landlords or tenants, do not invalidate it. The tenancy can end only at the end of a rental period, and for a year-to-year tenancy that is the end of the rental year even where rent is paid monthly. A notice naming the first day of the next rental period instead of the last day of the current one is still good; if the tenant gave it the landlord may require the tenant to leave on the last day of the period, and if the landlord gave it the tenant may stay to the day named. A notice naming any other wrong date is valid but takes effect on the first date it could properly have named, unless the party receiving it chooses to treat the stated date as the effective one. Three things replace notice altogether: an express agreement on another method of termination proved by clear and convincing evidence, a surrender of the premises, and a periodic tenant who moves out without notice and misses rent. Faster routes for an imminent threat of serious physical harm and for nonpayment, criminal activity or another breach sit outside this section and are covered on the eviction page.

No: no statewide rule requires a reason, and no statute expressly authorizes local ordinances.

Local ordinances: no statute or decision addresses them. No Wisconsin statute addresses local just-cause or eviction-control ordinances, either to permit them or to forbid them. That silence sits inside a heavily preempted field. Section 66.0104 forbids every city, village, town and county from adopting a closed list of landlord-tenant ordinances covering tenant screening information, security deposits and inspections, a tenant's responsibility for damage to the premises, required communications to tenants or the municipality, inspection, registration, certification and licensing programs, and occupancy or transfer-of-tenancy fees. Section 66.1015 separately bars any local regulation of the amount of rent or fees charged for a residential unit, and the rent-increase page carries that preempted rent posture. Neither list reaches the grounds on which a tenancy may be ended, notice periods, or non-renewal. The state's residential rental-practices rules yield to a local ordinance unless the two are in direct conflict, meaning one can be obeyed only by breaking the other.

No reason is required to end a periodic tenancy in Wisconsin or to let a fixed term expire. The words good cause, just cause, for cause, without cause and no cause appear nowhere in the landlord and tenant chapter, and the notice itself need only state the intent to terminate and the date. The chapter regulates grounds in the other direction. Sections 704.16 and 704.17 give a landlord faster routes on stated grounds, and section 704.44 makes a residential agreement void where it lets the landlord end a tenancy for a crime of which the tenant or a lawful resident was the victim, or for a crime committed in relation to the property where the agreement omits the required domestic-abuse notice. The residential rental-practices rules separately bar a landlord from ending a tenancy, or giving notice preventing an automatic renewal, in retaliation for a tenant's complaint, tenant-organizing activity, or assertion of a tenant right, which the habitability page covers.

The term ends on its date; no statute requires notice from either side.

After the term, the landlord chooses whether a holdover becomes a new tenancy, typically by accepting rent. A holdover becomes a new tenancy only if the landlord elects to hold the tenant to one. Accepting rent for any period after the lease ends, or any other conduct showing the landlord means to let the tenant stay, is that election, unless the landlord has already started proceedings to remove the tenant. The new tenancy is month to month, or weekly or daily where the lease set rent on that basis, on the same terms as the old lease except that a right to renew, to extend, or to buy the premises, and any restriction on the landlord selling without first offering the property to the tenant, do not carry over. The lease may displace the whole of this rule by agreement, either in the lease itself or later, and no heightened proof is needed to do so.

Automatic-renewal reminder: The landlord must send the tenant a separate written notice calling attention to the automatic-renewal clause, delivered by the same methods a termination notice uses, at least 15 days and not more than 30 days before the date the lease sets for the tenant to give notice against renewal. Both ends of that window bind: a reminder sent too early fails as surely as one sent too late. Because the window runs back from the tenant's own opt-out deadline rather than from the end of the lease, a lease requiring the tenant to opt out 60 days before expiry puts the landlord's reminder window 75 to 90 days before expiry. Without the reminder the renewal clause is unenforceable against the tenant, though the rest of the lease stands. The state's residential rental-practices rules impose the same 15-to-30-day window but count it back from the renewal's stated effective date instead, and enforcing a clause without that notice is an unfair trade practice.

A lease for a fixed term ends on its own date. The 28-day notice section reaches only periodic tenancies and tenancies at will, and no Wisconsin statute requires either side to give notice that a fixed term will not be renewed. If the tenant stays on, the landlord may elect to hold the tenant month to month. One statute does constrain automatic-renewal clauses: section 704.15 makes an automatic renewal or extension clause in a residential lease unenforceable against the tenant unless the landlord sent the written reminder described above. The two counting rules for that reminder, one in the statute and one in the residential rental-practices rules, start from different events, so a landlord who satisfies one may miss the other, and a violation of the rules is an unfair trade practice carrying twice the tenant's loss together with costs and reasonable attorney fees.

A tenant who stays after a lease expires, or after a tenancy is ended by notice or by valid agreement, holds nothing: the landlord may proceed in any manner the law permits to remove the tenant and to recover damages for the holding over, with no further notice required. If instead the landlord elects to let the tenant stay, the tenant becomes a month-to-month tenant, and that new tenancy is then ended by the ordinary 28-day notice.

Damages: Double rent for the holdover period. Qualifiers: the statutory figure is a minimum, not a ceiling; and prorated by the day.

Where the tenant stays without the landlord's consent, the landlord recovers the damages actually suffered, and in the absence of proof of greater damages recovers as a minimum twice the rental value apportioned by the day for the time the tenant remained. The doubling is a floor rather than a ceiling, and the statute expressly preserves any other damages the landlord can prove. Rental value means what the premises might reasonably have been rented for, but never less than what the tenant paid or owed for the previous rental period, and it includes the money value of obligations the tenant took on, such as taxes, insurance or repairs. A holdover the landlord consents to is not a damages event at all; consent is the election that creates a new month-to-month tenancy instead.

Yes: a statute imposes the duty.

When it attaches: The duty attaches when the tenant leaves before the termination date without justification and misses rent, and equally when the tenant is removed for failing to pay rent or for any other breach of the lease. It does not attach where the landlord has expressly agreed to accept a surrender of the premises and to end the tenant's liability.

Burden of proof: split, with different elements on each side.

The standard: Reasonable efforts are defined in the statute itself as the steps the landlord would have taken to rent the premises had they been vacated in due course, provided those steps are in accordance with local rental practice for similar properties. The recovery is reduced by the net rent obtainable by those efforts, and in the absence of proof that more was obtainable the tenant is credited with the rent actually received under a re-rental, less expenses reasonably incurred, including a fair proportion of any remodeling or other capital improvement. The landlord may add the reasonable costs of listing and advertising in re-renting and attempting to re-rent. A landlord who has other similar premises for rent may fill those first from an offer the departing tenant did not produce. Entering with or without notice to inspect, preserve, repair, remodel or show the premises, re-renting with or without notice, and using the premises for up to a year on prompt written notice crediting the tenant with the reasonable value of that use are all privileged, and none of them counts as accepting a surrender.

A lease clause accelerating all remaining rent on default is void.

The lease may not waive the duty.

Wisconsin imposes the duty by statute, in section 704.29, and applies it to a tenant under a lease, a periodic tenant, and an assignee of either. The burden is split, and the statute allocates it precisely: the landlord must allege and prove that efforts to comply were made, and the tenant then bears the burden of proving that those efforts, the refusal of an offer to rent, the terms of an actual re-rental or a temporary use by the landlord were not reasonable, and of proving the amount that could have been obtained. A lease cannot escape any of this. A residential rental agreement that provides for acceleration of rent on the tenant's default, or that otherwise waives the landlord's duty to mitigate, is void and unenforceable, and because that provision overrides the ordinary rule saving the rest of an agreement, the whole agreement falls rather than the clause alone. The same conduct is an unfair trade practice under the residential rental-practices rules. Every precedential Wisconsin appellate decision construing the mitigation statute arose from a commercial lease; the only decision applying it to a residential tenancy is unpublished and by rule carries persuasive weight only, so the residential answer rests on the statute's own words, which reach residential tenancies expressly.

No statute addresses a fee a landlord may charge for ending a lease early; the general damages rules govern.

No Wisconsin statute authorizes, caps, or bars a fee, buy-out or liquidated sum for ending a residential lease early, and neither the list of provisions that make a residential agreement void nor the residential rental-practices rules contains any such item. What a departing tenant owes is set by the mitigation statute instead: rent and damages, reduced by the net rent the landlord could obtain by reasonable efforts to re-rent. Three structural limits do the work a fee cap does elsewhere. A clause accelerating the remaining rent on default, or waiving the mitigation duty, makes the entire residential agreement void. A clause requiring the tenant to pay the landlord's attorney fees or costs in a dispute arising under the agreement does the same, though a court may still award costs under its own small-claims and civil-procedure rules. And the doubled holdover figure is a minimum award for staying on without consent, not a charge for leaving early. The state's administrative rental-practices rules were read for this answer and contain no fee provision of any kind.

Early-exit rights by ground: domestic violence and related grounds, a statutory right to end the lease; military service beyond the federal act, state orders or National Guard duty are covered; death of the tenant, a statutory route.

Domestic violence and related grounds: a victim may end the lease on notice.

Who qualifies: A residential tenant who holds one of the enumerated court or charging documents, protecting the tenant or a child of the tenant. The grounds behind those documents are domestic abuse, child abuse, stalking and sexual assault. Wisconsin never asks whether the tenant is a victim; it asks which document the tenant produces. Human trafficking is not a listed ground.

Separate schemes: There are two doors. The first covers domestic abuse, child abuse, stalking and a no-contact condition of release, and it requires the tenant or a child of the tenant to face an imminent threat of serious physical harm if the tenant stays on the premises, in addition to the document. The second, created by 2025 Wisconsin Act 90 and in force since March 8, 2026, covers sexual assault and requires only the document. Before that date a sexual-assault survivor had to show the imminent threat as well, because the sexual-assault injunction sat inside the first door; the 2026 act moved it out and dropped that element.

Documentation: A certified copy of one of the listed documents, given to the landlord together with the notice. For the first door those are an injunction protecting the tenant from the person under the domestic-abuse or child-abuse injunction statutes; a harassment injunction based on the person's stalking or attempting or threatening to stalk; a condition of release ordering the person not to contact the tenant; a criminal complaint alleging that the person stalked the tenant or a child of the tenant; or a criminal complaint filed after the person was arrested for a domestic-abuse offense against the tenant. For the second door they are a harassment injunction based on sexual assault, or a criminal complaint alleging sexual assault of the tenant or a child of the tenant. The list is closed: a police report, a statement from a victim advocate or other qualified third party, and a tenant's own certification are all insufficient. The notice and the documentation go to the landlord together.

Window: The statute sets no time limit between the incident, or the date of the court document, and the tenant's notice. A certified copy of a qualifying order or complaint works whenever the tenant produces it.

Notice: The statute states no advance-notice period and no waiting time. The tenant gives written notice by the ordinary delivery methods, together with the certified copy, and may remove from the premises. What limits the tenant is not a notice period but the rent that keeps running for a time after the notice.

Rent owed: The tenant is not liable for rent after the end of the month following the month in which the tenant gives the notice or moves out, whichever of those two is later. A tenant who gives notice in March and moves out in March therefore stops owing rent at the end of April; a tenant who gives notice in March but leaves in May owes through the end of June. That liability is subject to the landlord's duty to mitigate, so a landlord who re-rents inside the window credits the tenant with what the new tenancy brings in.

Cost to the tenant: No statutory fee, penalty or liquidated charge attaches to the termination. The tenant does pay the cost of changing the locks where a lock change is requested. The deposit is returned under the ordinary deposit rules, which the security-deposit page covers.

Other tenants on the lease: the lease continues for the other tenants. The statute releases nobody but the tenant who terminates, and it expressly keeps the person named in the court document liable under the agreement where that person is also a tenant of the same premises. It says nothing at all about an innocent co-tenant, so on the face of the text a co-tenant who is not the person named stays bound.

Locks: The victim may require the landlord to change the locks. A tenant who gives the landlord a certified copy of a qualifying document may require a lock change whether or not the tenant also ends the tenancy. The landlord must have the locks changed, or give the tenant permission to change them, within 48 hours of receiving the request and the certified copy, and the tenant bears the cost; a tenant who changes them must give the landlord a key within a reasonable time. Where the person named in the document is also a tenant of the same premises, the duty arises only if the document directs that person to avoid the requesting tenant's residence or orders that person not to contact the requesting tenant. A landlord is not liable in civil damages for anything done to comply.

Later screening: no statutory protection.

The landlord's side: The landlord may insist on the certified copy before anything happens, and is protected from civil damages for complying with the lock-change duty. Separately, the landlord may end the tenancy of an offending tenant whose acts, including verbal threats, cause another tenant or that tenant's child living in the same single-family rental unit, multiunit dwelling or apartment complex, or in the same manufactured or mobile home community, to face an imminent threat of serious physical harm, where the offending tenant is the person named in one of the qualifying orders or complaints. That termination takes written notice requiring the offending tenant to leave on a date at least five days after the notice is given, stating the basis for it and the tenant's right to contest it in an eviction action; if the tenant does contest it, the landlord must prove the allegations by the greater weight of the credible evidence.

Lease disclosure: Every residential rental agreement must include a prescribed notice of domestic abuse protections, in the agreement itself or in an addendum. The prescribed text tells the tenant about the defense available in an eviction action where the landlord knew or should have known the tenant is a victim of domestic abuse, sexual assault or stalking and the eviction is based on conduct related to it; about the limited right to end the agreement; and that the notice is only a summary and the statutes govern. The consequence of leaving it out is severe. Where the agreement also allows the landlord to end the tenancy for a crime committed in relation to the rental property, omitting the notice makes the entire agreement void and unenforceable, not merely the offending clause. In Koble Investments v. Marquardt, 2024 WI App 26, the Court of Appeals applied that result to a lease that prohibited using the premises for an unlawful purpose and omitted the notice, and held it made no difference that the clause might have been valid under the for-cause notice section.

A residential tenant may end the tenancy and leave by giving the landlord written notice, delivered the ordinary way, together with a certified copy of one of the enumerated court or charging documents. Under the first door the tenant must also face an imminent threat of serious physical harm to the tenant or a child of the tenant if the tenant stays; under the second, added in 2026 for sexual assault, the document alone is enough. There is no advance-notice period, no time limit on how old the document may be, and no fee. Rent stops at the end of the month following the month of the notice or of the move-out, whichever is later, subject to the landlord's duty to re-rent. Separately, and without terminating, a tenant who produces a qualifying document may require the landlord to change the locks within 48 hours at the tenant's cost. Nothing in the section shields the tenant from being asked about the termination by a later landlord or screening service, and no confidentiality duty attaches to the documents the landlord receives.

Military service: State orders or National Guard duty are covered.

When the state rights attach: The right reaches only a lease executed by or on behalf of the service member before entering state active duty, and only where the orders are for 30 days or more. It covers premises occupied for dwelling, professional, business, agricultural or similar purposes by the member, or by the member and dependents. A dependent has no termination right of their own; dependents are protected instead by the section's separate stay of eviction. The section cannot be given up by a lease signed beforehand: only a written agreement made during or after the period of state active duty can displace it.

Wisconsin has its own servicemember civil relief law, section 321.62, and it reaches members of the National Guard and the state defense force ordered into state active duty for 30 days or more, a group the federal act does not cover. Such a member may end the lease at any time after the period of state active duty begins by written notice delivered personally or by first-class mail to the landlord or to whoever has been receiving the rent or managing the property. Where the lease provides for monthly rent, the termination takes effect 30 days after the first date the next rent payment falls due after the notice is delivered or mailed. In any other case it takes effect on the last day of the month after the month of the notice, unpaid rent for the period before termination is computed pro rata, and the landlord refunds any rent paid in advance for the period after it. Two features are unusual. The landlord may apply to a court after receiving the notice and before the termination date, and the court may modify or restrict the relief as it thinks appropriate. And the mitigation statute expressly does not apply to a termination under this section, so the ordinary re-letting machinery drops away. Knowingly seizing or holding the departing member's property, or interfering with its removal, to secure rent accruing after the termination is a crime carrying a fine of up to $10,000, imprisonment for up to nine months, or both.

Death of the tenant: A statute provides for ending the lease on the tenant's death. The tenancy of a residential tenant who dies ends automatically, on the earlier of two dates: 60 days after the landlord receives notice of the death, is told of it, or otherwise becomes aware of it, and the expiration of the term of the rental agreement. No one has to serve the landlord with anything; the landlord's awareness, however it arises, starts the clock. For a periodic tenant or a tenant at will the 60-day rule applies despite the ordinary 28-day notice section, so no termination notice is needed. Neither the deceased tenant nor the estate is liable for rent after the tenancy ends, and that liability is subject to the landlord's duty to mitigate. Another adult tenant of the same premises stays bound by the agreement. A landlord may not contact or communicate with a member of the deceased tenant's family for the purpose of obtaining rent the family member has no liability for.

Notice is treated as given on the day the landlord learns of the abandonment, and the tenancy ends when that notice would have taken effect.

Wisconsin has one abandonment rule and it is a single sentence. Where a periodic tenant vacates the premises without notice to the landlord and fails to pay rent when it falls due for any period, the tenancy ends on the first date it would have ended had the landlord been given a proper notice on the day the landlord learns of the removal. In practice that means 28 days from the day of discovery, rolled forward to the end of that rental period, or one rent-paying period for a tenancy shorter than monthly. There is no absence period to count, no notice of belief of abandonment for the landlord to serve, and no window for the tenant to answer; the rule is one of the three express exceptions to the written-notice requirement. It ends the tenancy, but it does not end what the tenant owes, which is governed by the mitigation statute and reduced by the re-letting credit, so a tenant who abandons does not simply walk away from the rest of the lease. What a landlord may do with property left behind is covered separately.

One statute governs the delivery of every notice under the chapter, termination notices included, and it gives the two sides different lists. A landlord, or someone acting for the landlord, must use one of five methods: giving a copy personally to the tenant, or leaving a copy at the tenant's usual home in the presence of a competent member of the tenant's family at least 14 years old who is told what it contains; leaving a copy with any competent person apparently in charge of or occupying the premises and mailing a copy to the tenant's last-known address; if neither of those can be done with reasonable diligence, posting a copy conspicuously on the premises where it can be conveniently read and mailing a copy to the last-known address; mailing a copy by registered or certified mail to the last-known address; or serving the tenant the way a court summons is served. A tenant has four, and no posting route: personal delivery to the landlord or to anyone who has been receiving the rent or managing the property, or to a competent adult family member at the landlord's home; personal delivery to a competent person apparently in charge of the landlord's regular place of business or the place where rent is payable; registered or certified mail to the landlord or the rent-collecting agent; or service as for a summons. Personal delivery to a corporation may be made only to an officer, director, registered agent or managing agent, or left with an employee in that person's office during business hours, with a matching rule for partnerships.

Electronic delivery: the statute lists the permitted methods and excludes it.

Mailing: 1 day is added to the period when the notice is mailed. The rule applies only to a notice sent by registered or certified mail. Such a notice counts as given on the second day after the day of mailing where it is addressed to a point within Wisconsin, and on the fifth day after mailing in every other case, and that day is counted as the first day of the notice period, so mailing effectively adds one day in state and four out of state before the 28 days begin to run. It is a floor built into when a notice counts as given, not a cap on how far mailing may push a tenancy out. Where the notice is left with a person at the premises or posted, it counts as given on the day of leaving or posting or the date of mailing the copy, whichever is later; where improper delivery is cured by actual receipt, it counts as given on the day of receipt.

What the notice must contain: The notice must be in writing, may be formal or informal, and must substantially inform the other party of the intent to end the tenancy and of the termination date. Errors that do not mislead do not invalidate it, expressly including the omission of the name of one of several landlords or tenants, and an inaccurate termination date is cured forward rather than fatal. Notice given to one of two or more landlords, or to one of two or more co-tenants of the same premises, counts as notice to the others. A notice not properly delivered is still good if the other party actually received it, but the party claiming receipt must prove it by clear and convincing evidence. The landlord-side notice ending an offending tenant's tenancy carries one extra content rule: it must state the basis for its issuance and the tenant's right to contest the termination in an eviction action.

Wisconsin has not written the federal 30-day termination notice for covered dwellings into its own law, and no state statute or administrative rule refers to it. A landlord of a covered dwelling who relies on the 28-day state notice is short of the federal 30 days. Wisconsin's own servicemember civil relief law, section 321.62, does extend lease-termination protection beyond the federal servicemember act, to National Guard and state defense force members ordered into state active duty for 30 days or more.

The federal CARES Act 30-day notice to vacate for covered properties, as read in this state's courts: no state appellate decision construes it. No Wisconsin appellate decision construes the federal 30-day notice provision. There is no standing court order or filing requirement a Wisconsin landlord would meet either, so the federal requirement stands on its own terms above the state's 28 days with no state authority construing it in either direction. (Appellate picture read as of September 4, 2026.)

Vander Wielen v. Van Asten, 2005 WI App 220, 287 Wis. 2d 726, 706 N.W.2d 123 (Wisconsin Court of Appeals; arose from a commercial lease; bears on the duty to re-let): Whenever a landlord does not, by word or deed, accept the surrender of leased premises after a tenant leaves, the landlord must mitigate damages by attempting to re-rent; and a landlord who elects to hold the tenant to the tenancy does not accept a surrender merely by re-renting to someone else, because re-renting standing alone is an equivocal act. The case arose from a commercial lease of part of a building used for a laundry and dry-cleaning business, and the court applied the holdover limb that is expressly non-residential, so its force for a dwelling comes from the mitigation statute's own words rather than from these facts.

Kersten v. H.C. Prange Co., 186 Wis. 2d 49, 520 N.W.2d 99 (Wis. Ct. App. 1994) (Wisconsin Court of Appeals; arose from a commercial lease; bears on the duty to re-let): A trial court may retain jurisdiction to determine damages for rent not yet due, and the mitigation expenses a landlord may recover are limited to necessary expenses actually incurred; they do not include compensation for the time the landlord spent mitigating. The dispute arose from a ten-year commercial lease of office space, so the holding reaches a dwelling only through the mitigation statute, which applies to both.

Butler Plaza, LLC v. Curtis, No. 2018AP1612 (table, 387 Wis. 2d 686, 928 N.W.2d 812) (Wisconsin Court of Appeals, 2019; residential lease; bears on the duty to re-let): Applying the mitigation statute to a residential lease, the court held that once the landlord proved it had re-rented the premises and had therefore made an effort to mitigate, the burden shifted to the tenants to prove that the terms on which the landlord actually re-rented were not reasonable, and that the landlord was not required to take any special steps to re-rent. The decision is unpublished and was issued by a single judge, so under the state's citation rule it may be cited for its persuasive value only and does not bind later courts.