State v. Buelow

In State v. Buelow, 122 Wis 2d 465, 363 NW2d 255 [1984], the Wisconsin court set forth a series of factors including foremost, "the natural tendency to place the burdens on the party desiring change" and added as the party desiring free services, the defendant should bear the burden of proof. (122 Wis 2d at 471, 363 NW2d at 259.) In addition, because the defendant is the party in possession of all the material proof regarding her own wealth, and is asserting the negative--lack of funds--the court held that she should be required to come forward with proof. (122 Wis 2d at 472, 363 NW2d at 259.)