Manitowoc County v. Harlan H., 2011AP2499-FT, District 2, 1/25/12 court of appeals decision (1-judge, not for publication); for Harlan H.: Shelley Fite, SPD, Madison Appellate; case activity Evidence that Harlan had put his wife in a headlock on one occasion and physically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
f. 51.20(1)(a)2. Dangerousness
Outagamie County v. Lorna G., 2011AP1662, District 3, 10/25/11 court of appeals decision (1-judge, not for publication); for Lorna G.: Eileen A. Hirsch, SPD, Madison Appellate; case activity Although the trial court’s reference to “potential” for harm was an “imprecise summary” of the §51.20(1)(a)2b test for commitment (“substantial probability of physical harm”), this articulation “was… Read more
Barron County v. Dennis H., 2010AP1026, District 3, 10/19/10 court of appeals decision (1-judge, not for publication); for Dennis H.: Jefren E. Olsen, SPD, Madison Appellate Evidence held sufficient to support finding of dangerousness. 1) Recent overt act, attempt or threat to do serious physical harm. A psychologist testified that Dennis at times displayed aggressive behavior (“he… Read more
State v. Dennis H., 2002 WI 104, on certification For Dennis H.: Ellen Henak, SPD Milwaukee Appellate Issue: Whether the “fifth standard” for mental commitment, § 51.20(1)(a)2.e. (roughly: refusing treatment due to incapacity for making rational treatment decision), is constitutional. Holding: The statute isn’t vague — the state must prove the various “elements” of this standard (which the… Read more
