Ozaukee County v. S.S., 2024AP759, District II, 9/11/24 (one-judge decision; ineligible for publication); case activity In determining whether to continue protective placement under Chapter 55, the County does not need to present an expert witness to establish an individual continues to meet the criteria for placement, and the circuit court may rely on the entire… Read more
C. Ch. 55, Protective placement
Washington County v. T.R.Z., 2024AP21, District II, 6/19/24 (one-judge decision; ineligible for publication); case activity Although “Tim’s” appeal presents several issues for review, COA dismisses the appeal as moot given the existence of an intervening Watts review. Tim has been under guardianship and protective placement orders since 2021. (¶3). This is an appeal of an order continuing… Read more
Outagamie County DHHS v. L.C.E., 2023AP929, District 3, 6/4/24 (one-judge decision; ineligible for publication); case activity There was insufficient evidence for the protective placement order because the County failed to prove that “Lauren” was “so totally incapable of providing for . . . her own care or custody as to create a substantial risk of… Read more
Douglas County v. M.L, 2022AP141, 12/28/23, District III (one-judge decision; ineligible for publication); case activity Faced with a challenge to the circuit court’s competency in this protective placement appeal, COA holds that the appellant has forfeited his challenge and therefore affirms. “Mason” appeals an order continuing his protective placement following a due process review hearing… Read more
Douglas County v. J.M., 2022AP2035, 11/28/23, District 3 (one-judge decision; ineligible for publication); case activity “James” was subjected to a guardianship under ch. 54 and a protective placement under ch. 55 in 2020. He had annual reviews of placement in 2021 and 2022; the last one is the subject of this appeal. James argues… Read more
Racine County v. B.L.M., 2023AP757, 11/22/23, District II (ineligible for publication); case activity Despite a creative challenge to a continued protective placement order, COA rejects any argument that the circuit court lost competency by failing to timely reappoint a GAL in this protective placement appeal. § 55.18 lists the required procedures for an annual review… Read more
Waukesha County DHHS v. M.S., 2022AP2065, District 2, 9/6/23 (one-judge decision; ineligible for publication); case activity (briefs not available) M.S. (“Martin”) spent nearly 22 years committed under Chapter 51. In 2021, the county switched course and sought and received a permanent guardianship and protective placement under Chapters 54 and 55. Martin challenged whether he was a… Read more
Price County v. C.W., 2023AP18-FT, District III, 9/6/23 (one-judge decision; ineligible for publication); case activity Under the specific facts of this case, COA holds that the County was not required to call a medical expert at “Clara’s” protective placement hearing and affirms. In the fall of 2021, Clara stipulated to a guardianship under Chapter 54… Read more
