Monroe County v. H.K.B., 2024AP1305, District 4, 1/16/25 (one-judge decision; ineligible for publication); case activity On appeal from the two most recent Watts review hearings, the COA concludes that there was insufficient evidence for the protective placement order because the County failed to prove that H.K.B. was “so totally incapable of providing for . … Read more
3. Civil Commitments
Wood County v. P.J.L., 2024AP2098-FT, 1/9/25, District IV (one-judge decision; ineligible for publication); case activity In a chapter 55 appeal arising from a somewhat unusual posture–a continued protective placement order following a jury trial–COA’s invocation of an exceedingly deferential standard of review results in affirmance. P.J.L. has been under a protective placement since 2021. (¶5)… Read more
Outagamie County v. M.J.B., 2024AP250, 1/7/25, District III (recommended for publication); case activity In a case clarifying a legal question that has persisted for years in 51 litigation, COA holds that when the examiners do not satisfy the statutorily-imposed deadline for filing their reports in connection with a final hearing in an original commitment proceeding… Read more
Dane County v. M.A.A., 2024AP1589, 12/27/24, District IV (one-judge decision; ineligible for publication); case activity The Court of Appeals affirmed the circuit court’s order authorizing involuntarily administering medication to M.A.A. in light of evidence that M.A.A. denies he has a mental illness. M.A.A. was committed under Chapter 51 due to a history of schizophrenia spectrum… Read more
State v. D.E.C., 2024AP1789-CR & 2024AP1799-CR, 12/27/24, District IV (recommended for publication); case activity In yet another published decision pertaining to an involuntary medication order entered in conjunction with pretrial competency proceedings, COA holds that the testimony of a treating psychiatrist, in conjunction with the proposed treatment plan, was legally sufficient and affirms the order… Read more
Monroe County v. M.C., 2024AP924, 12/12/24, District IV (one-judge decision; ineligible for publication); case activity The Court of Appeals reversed the circuit court’s commitment order under Chapter 51 where the court did not make sufficient factual findings to support its conclusion that M.C. was dangerous, as required by D.J.W. Police issued a statement of emergency… Read more
Trempealeau County v. R.B., 2024AP1052, 12/10/24, District III (one-judge decision; ineligible for publication); case activity COA affirms, holding that the evidence of potential deterioration during commitment period justified extension order. “Rachel” was originally committed in July of 2023 due to concerns that she would harm herself given that she was hearing voices telling her kill… Read more
Vernon County v. F.W.R., 2024AP203, District IV, 11/6/24 (one-judge decision; ineligible for publication); case activity COA rejects F.W.R.’s challenges to his involuntary commitment order under Wis. Stat. § 51.20 for alcohol dependence, concluding that a person may be involuntarily committed for treatment for alcoholism, the circuit court followed the proper procedures and the county met… Read more
