¶ 1. Jody Bradley, warden of the North Fork Correctional Facility in Oklahoma, appeals a nonfinal order denying his motion to dismiss a certio-rari action filed by Tommy Ponchik, a Wisconsin inmate seeking review of an out-of-state prison disciplinary decision. Warden Bradley contends that Wisconsin *770courts lack competency to review the disciplinary decision and also lack personal jurisdiction over Bradley. We need not reach the Warden's personal jurisdiction argument because we agree that the trial court lacked competency to entertain Ponchik's certiorari action. In keeping with State ex rel. Myers v. Swenson, 2004 WI App 224, 277 Wis. 2d 749, 691 N.W.2d 357, a decision we also issue today, we conclude the trial court lacked competency to address the merits of Ponchik's certio-rari action because Ponchik failed to show both that he sought judicial review in Oklahoma and that he was denied review because the Oklahoma court determined it lacked either jurisdiction or competency. Accordingly, we reverse the order of the trial court and remand with directions that the writ be quashed and the certiorari action be dismissed.
Background
¶ 2. Ponchik is a Wisconsin inmate who was transferred to the North Fork Correctional Facility in Oklahoma pursuant to a contract between the Wisconsin Department of Corrections and the Corrections Corporation of America, a private company. Prison officials at North Fork Correctional issued Ponchik a conduct report for assault and failure to follow posted rules. A disciplinary committee found Ponchik guilty of the assault charge and imposed a punishment of thirty days in the special management unit. The assistant warden at North Fork Correctional denied Ponchik's administrative appeal.
¶ 3. While still incarcerated in Oklahoma, Pon-chik filed a petition for a writ of certiorari in Wisconsin, naming both Bradley, in his capacity as the Warden at North Fork Correctional, and Matthew Frank, in his capacity as the Secretary of the Wisconsin Department of Corrections, as respondents. It appears that, shortly *771after filing this petition, Ponchik was transferred back to Wisconsin. The Wisconsin trial court issued a writ directing prison officials to file a return of the administrative record.
¶ 4. While the Wisconsin certiorari 'action was pending, Ponchik wrote to the clerk of court in Beck-ham County, Oklahoma, where North Fork Correctional is located. In his letter, Ponchik requested forms to file a certiorari action in Oklahoma and inquired whether it was true that Oklahoma does not conduct certiorari reviews. The clerk responded that she was unable to provide legal advice, and directed Ponchik to the prison law library.
¶ 5. Warden Bradley moved to quash the writ and dismiss the action on the grounds that the court lacked personal jurisdiction over Bradley and lacked competency to review inmate discipline at an out-of-state contract facility.1 The trial court denied Warden Bradley's motion, and Bradley sought interlocutory review. This court granted leave to appeal the nonfinal order on December 15, 2003.
Discussion
¶ 6. We independently review whether a trial court is competent to proceed on a certiorari action. Myers, 277 Wis. 2d 749, ¶ 6. In Myers, we concluded that Wis. Stat. § 302.02(3t) (2001-02)2 deprives Wiscon*772sin courts of competency to conduct certiorari review of out-of-state prison disciplinary decisions, unless an inmate can show that he was denied judicial review on jurisdictional or competency grounds in the state where the disciplinary action occurred. Myers, 277 Wis. 2d 749, ¶¶ 9, 19. The inmate in Myers was unable to make the required prima facie showing because he merely asserted that it would be futile to seek out-of-state judicial review, without actually having attempted to obtain such review. Id., ¶¶ 2, 14.
¶ 7. Like the inmate in Myers, Ponchik failed to make a prima facie showing that a court in the state where the disciplinary action occurred concluded that it lacked jurisdiction or competency to review the discipline. Ponchik, however, makes two additional arguments that were not made by the inmate in Myers. First, Ponchik argues, in effect, that there is no need for an individualized showing because an Oklahoma statute precludes jurisdiction over all out-of-state prisoners housed there. See Okla. Stat. tit. 57, § 563.2(k) (2001). Second, Ponchik contends that he actually sought judicial review by writing to a clerk of court in Oklahoma. Although we did not address either of these specific arguments in Myers, we conclude our holding there nonetheless controls the result in this case and dictates that the Wisconsin trial court lacked competency to entertain Ponchik's certiorari action.
¶ 8. As we noted in Myers, whether an inmate has been denied access to an out-of-state court on jurisdic*773tional or competency grounds presents a factual question. Myers, 277 Wis. 2d 749, ¶ 13. Treating the question as factual in nature relieves Wisconsin courts of the need to continually review the laws of other states to determine what judicial relief is available in those states for disciplinary actions involving Wisconsin inmates. Such review of the jurisdictional laws of other states would be inefficient and would present an unnecessary burden on the courts of this state when the courts of other states are in the best position to interpret their own laws. Focusing on whether out-of-state judicial review was actually denied on jurisdictional or competency grounds, as a factual matter, also affords additional protection to inmates by providing an avenue for relief in Wisconsin in the event that an out-of-state court declines to exercise jurisdiction notwithstanding state laws that would otherwise appear to confer jurisdiction. Thus, we reiterate that, in order to establish that a Wisconsin court is competent to review an out-of-state disciplinary proceeding, an inmate must make an individualized showing that he has attempted to obtain judicial review in the state where the discipline was imposed and that a court in that state dismissed his case for lack of jurisdiction or competency. Id., ¶ 12. Ponchik's untested theory as to why judicial review would be unavailable under the laws of Oklahoma is insufficient to show that he would have been denied judicial review on jurisdictional or competency grounds.
¶ 9. Ponchik's correspondence with a clerk of court in Oklahoma is also insufficient to show that he was actually denied judicial review on jurisdictional or competency grounds. First, a letter from a clerk of court is not a judicial decision. Second, the clerk's letter did not address whether Oklahoma had jurisdiction. Finally, Ponchik did not even make his inquiry until after the *774certiorari action in Wisconsin had been filed.
¶ 10. In sum, Ponchik has failed to establish grounds to exempt his certiorari action from the general rule that Wisconsin courts lack competency to review out-of-state disciplinary decisions. Accordingly, we conclude that the trial court erred in denying Warden Bradley's motion to quash the previously issued writ and to dismiss the certiorari action. We therefore reverse and remand with directions that the trial court grant the Warden's motion. In light of our decision, we do not address the Warden's additional argument regarding personal jurisdiction.
By the Court. — Order reversed and cause remanded with directions.
Secretary Frank joined Warden Bradley's motion with respect to the competency issue, but did not separately appeal the trial court's ruling.
Wisconsin Stat. § 302.02(3t) provides: "For all purposes of discipline and for judicial proceedings, each institution that is located in another state and authorized for use under s. 301.21 *772and its precincts are considered to be in the county in which the institution is physically located, and the courts of that county have jurisdiction of any activity, wherever located, conducted by the institution." All references to the Wisconsin Statutes are to the 2001-02 version unless otherwise noted.