Parsons v. Associated Banc-Corp (WOCCA and Negligent Training & Supervision)

In Parsons v. Associated Banc-Corp (2018AP2329), the Court of Appeals District I upheld the dismissal of plaintiffs’ claims against their bank for violation of the Wisconsin Organized Crime Control Act (WOCCA) and for negligent training and supervision.

The Parsons filed this case regarding a home equity loan and construction loan they obtained through the bank. The trial court dismissed the Parsons claims and the appeals court affirmed.

The appeals court declined to overturn what the Parsons argued were several procedural errors by the trial court. On the WOCCA claim, the appeals court agreed with the trial court that the Parsons had not established that the bank’s loan officer had engaged in a pattern of racketeering; therefore, the bank had no liability under WOCCA. On the negligent training and supervision claim, the court found that the bank did not have a duty of care to the Parsons under the loan contract, so the bank was not liable for the loan officer’s actions. Finally, the court held that the trial court was not required to determine damages when the Parsons failed to establish the bank’s liability.

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