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A. Ch. 51, Mental health

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

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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

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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

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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

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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

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Waukesha County v. M.D.S., Jr., 2024AP1315, District II, 11/6/24 (one-judge decision; ineligible for publication); case activity COA rejects “Smith’s” challenges raising commonly-litigated appellate issues and affirms in this chapter 51 case, concluding that the circuit court applied the correct legal standard and the county met its burden to show that Smith was dangerous under sub… Read more

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State v. J.D.B., 2023AP715-CR, 9/10/24, District I (recommended for publication); case activity In a recommended-for-publication decision, COA wholly endorses all of J.D.B.’s arguments requiring a high burden of proof when the State seeks an involuntary medication order in order to render a defendant competent to stand trial. Along the way, COA offers a bevy of… Read more

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Brown County v. L.M.R., 2023AP2314, District III, 8/6/24 (one-judge decision; ineligible for publication); case activity COA rejects all of L.M.R.’s challenges raising commonly-litigated appellate issues and affirms in this Chapter 51 case given some less-than favorable facts. This is an appeal of an initial commitment order entered in 2022 after “Luke” was found wandering the… Read more

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