Miller v. Bristol-Myers Co
In Miller v. Bristol-Myers Co., 168 Wis. 2d 863, 879, 485 N.W.2d 31 (1992), the court recognized that the "representative capacity doctrine provides immunity to those who act in their capacity as a representative for the employer from third party suits."
There, the court refused to apply the doctrine to the parent corporation of the subsidiary employer. It observed that the "entity claiming immunity must owe a duty to the employer and have acted pursuant to that duty." Id. at 880.