On review of an unpublished court of appeals decision; case activity Issue (composed by On Point) Was there sufficient evidence to establish Michael H. was “dangerous” under § 51.20(1)(a)2.a. or c., based either on his “threats” of suicide or a pattern of acts or omissions showing such impaired judgment that there is a substantial probability… Read more
f. 51.20(1)(a)2. Dangerousness
Outagamie County v. Michael H., 2013AP1638-FT, District 3, 11/26/13 (1-judge decision, ineligible for publication), petition for review granted 6/12/14, affirmed, 2014 WI 127; case activity Michael H. challenges a jury verdict finding him “dangerous” under Wis. Stat. § 51.20(1)(a)2a and involuntarily committing him for mental health treatment. Given this procedural posture, the court of appeals’ holding seems… Read more
Winnebago County v. Gina A.R., 2013AP226, District 2, 5/22/13; court of appeals decision (1-judge; ineligible for publication); case activty The court rejects Gina A.R.’s claim that the evidence at the final hearing was insufficient to show she is mentally ill, a proper subject for treatment, and dangerous, noting that much of her argument discusses facts… Read more
Review of unpublished court of appeals decision; case activity Issues (composed by On Point) 1. Whether there was sufficient proof that Mary F.-R. evidenced a “substantial probability of physical harm” to herself or others and was therefore dangerous under Wis. Stat. § 51.20(1)(a)(2). 2. Whether Wis. Stat. § 51.20(11) is an unconstitutional violation of equal… Read more
Milwaukee County v. Cheri V., 2012AP1737, District 1, 12/18/12 court of appeals decision (1-judge, ineligible for publication); case activity Mental health commitment, § 51.20, requires proof of mental illness and dangerousness. Cheri V. limits this challenge to the latter; the court agrees: ¶7 As seen from our recitation of the facts adduced at the trial… Read more
Milwaukee County v. Mary F.-R., 2012AP958, District 1, 10/2/12; court of appeals (1-judge, ineligible for publication), petition for review granted 2/11/13; case activity Ch. 51 Commitment – Sufficiency of Evidence Evidence held sufficient to uphold commitment, on issue of “dangerousness,” State v. Poellinger, 153 Wis. 2d 493, 507, 451 N.W.2d 752, (1990), applied: ¶12 Here, the County had to prove… Read more
Trempealeau County v. Charles O., 2011AP2794, District 3, 5/1/12 court of appeals decision (1-judge, not for publication); for Charles O.: William E. Schmaal, SPD, Madison Appellate; case activity The court rejects Charles O.’s argument that the evidence fell short of the “fifth-standard” showing of dangerousness, § 51.20(1)(a)2.e., State v. Dennis H., 2002 WI 104, ¶14, 255 Wis… Read more
Manitowoc County v. Harlan H., 2011AP2499-FT, District 2, 1/25/12 court of appeals decision (1-judge, not for publication); for Harlan H.: Shelley Fite, SPD, Madison Appellate; case activity Evidence that Harlan had put his wife in a headlock on one occasion and physically resisted a deputy’s attempt to detain him another, coupled with a diagnosis of… Read more
