State ex rel. Universal Processing Services of Wisconsin, LLC v. Circuit Court for Milwaukee County, 2017 WI 26, 374 Wis. 2d 26, 892 N. W.2d 267
This case concerned whether a circuit court impermissibly delegated its power to a referee to decide litigation on the merits. Writing for the majority, Abrahamson noted that the Wisconsin Constitution vests the “judicial power” of the state in the courts. She surveyed the history of referees (also called “special masters”) from the time Wisconsin was a territory through modern federal practice. She held that while referees are a valuable adjunct to the judicial process, they may not assume the place of a judge.