## Facts

- Rhoda Lavinia Goodell had been admitted to practice in Wisconsin circuit courts and sought admission to practice before the Wisconsin Supreme Court.
- In 1875, the Wisconsin Supreme Court denied her application, interpreting the then-governing admission statute as not authorizing women to practice before the court.
- After that denial, the Wisconsin Legislature enacted a statute providing that no person may be denied admission or a license to practice as an attorney in any Wisconsin court on account of sex.
- In April 1879, counsel moved the Wisconsin Supreme Court to admit Goodell under the new statute.
- The motion presented no dispute about Goodell’s professional qualifications; the contested point concerned eligibility on the basis of sex in light of the statutory change.

## Issues

1. Whether, under Wisconsin Revised Statutes of 1878, § 2586, subd. 5, a qualified woman is entitled to admission to practice before the Wisconsin Supreme Court notwithstanding the court’s prior exclusionary interpretation.
2. Whether the court retained discretion to deny admission based on sex after the legislature directed that bar admission may not be denied on account of sex.

## Decision

- The Wisconsin Supreme Court granted the motion and admitted Goodell to practice before the court.
- The court treated the intervening statute as controlling and as superseding the practical effect of the earlier denial.
- The court applied a qualifications-based standard, recognizing sex as legally irrelevant under the statute.

## Legal Principles

- Where a statute provides that no person shall be denied a license to practice law on account of sex, an otherwise qualified applicant may not be excluded from bar admission because she is a woman.
- Legislative enactments may override a court’s prior construction of an admission statute; after such an enactment, judicial discretion must conform to the statutory nondiscrimination rule.
- Bar admission determinations must turn on professional qualifications rather than status-based exclusions prohibited by statute.

## Conclusion

The court admitted Goodell because Wisconsin law barred sex-based denial of attorney licensure, making admission mandatory for an applicant who met the requisite qualifications.


In re Goodell, 48 Wis. 693 (Wis. 1879)