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
c. Pattern of acts
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
Brown County v. J.D.T., 2023AP2339, 7/23/24, District 3 (one-judge decision; ineligible for publication); case activity J.D.T. challenges the his commitment under ch. 51 (second and third standards). The COA concludes that the county presented sufficient evidence of dangerousness under the third standard, Wis. Stat. § 51.20(1)(a)2.c., and therefore does not address the second standard. Wis… Read more
Ozaukee County D.H.S. v. M.A.G., 2023AP681, 11/29/23, District II (one-judge decision; ineligible for publication); case activity M.A.G. challenged the extension of her Chapter 51 commitment and the order finding her incompetent to refuse medication. The court of appeals affirms both orders after concluding that the county presented sufficient evidence of dangerousness under the the third… Read more
Winnebago County v. C.H., 2023AP505, 8/30/23, District 2 (one-judge decision; ineligible for publication); case activity In this Ch. 51 appeal, COA swats aside familiar 51 arguments, expresses its frustration with a “flood” of Ch. 51 appeals and, with approving citation to a dissent from SCOW, hints that we may not have heard the last of… Read more
Defense win! County failed to prove patient received a reasonable explanation of proposed medication
Marinette County v. A.M.N., 2022AP1395, District III, 8/29/23, 1-judge decision ineligible for publication; case activity (briefs not available) Faced with a weak record, COA holds that A.M.N. cleared imposing hurdles to relief and reverses the lower court’s medication order as there was no proof he received a reasonable explanation of the proposed medication. However, despite a… Read more
Marathon County v. T.R.H., 2022AP1394, 3/14/23, District 3 (1-judge opinion, ineligible for publication); case activity Counties often seek recommitment under §51.20(1)(a)2.c, the third standard of dangerousness. It is the easiest standard to satisfy–especially at the recommitment stage. But not this time. The court of appeals held that the county can’t just offer testimony that, at… Read more
Waukesha County v. G.M.M., 2022AP1207, 1/18/23, District 2, (1-judge opinion, ineligible for publication); case activity This appeal involves a recommitment under the 3rd standard of dangerousness. G.M.M. argued that the county presented insufficient evidence of both mental illness and dangerousness. She also argued that the circuit court failed to make the findings required under Langlade… Read more
