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f. 51.20(1)(a)2. Dangerousness

Rock County v. B.A.G., 2018AP782, 7/26/18, District 4, (1-judge opinion, eligible for publication); case activity B.A.G. challenged a court order to commit and medicate him under §51.20(1)(a)2e (the 5th standard). His main objection appears to be that being undressed outside in cold weather was insufficient evidence to commit him. The court of appeals does not articulate… Read more

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Milwaukee County v. I.K., 2017AP1425, District 1, 5/8/18 (one-judge decision; ineligible for publication); case activity The County proved I.K. was dangerous under both § 51.20(1)(a)2.d., by showing there was a substantial probability I.K. would suffer physical harm resulting from his inability to satisfy basic needs due to mental illness, and § 51.20(1)(a)2.e., by showing that, after being advised… Read more

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Chippewa County v. M.M., 2017AP1325, 5/1/18, District 3, (1-judge opinion, ineligible for publication); case activity You don’t see this very often. A jury found M.M. mentally ill, a proper subject for treatment, and dangerous under §51.20(1)(a)2.c based on testimony by not 1, not 2, but 3 doctors–all of whom said that M.M.’s paranoia and conduct would… Read more

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Outagamie County v. C.A., 2017AP450, District 3, 1/23/18 (1-judge opinion, ineligible for publication); case activity The records for Chapter 51 cases are confidential, so we have not seen the briefs for this case. But, judging from this court of appeals opinion, it doesn’t take much beyond a mental illness diagnosis to get yourself committed under §51.20(1)(a)2e… Read more

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Evidence supported dangerousness finding

Langlade County v. D.J.W., 2017AP1313-FT, District 3, 11/7/17 (one-judge decision; ineligible for publication); case activity There was sufficient evidence at D.J.W.’s commitment trial to establish he met the standard for dangerousness under § 51.20(1)(a)2.d. D.J.W. argues the evidence wasn’t sufficient to establish a recent failure to care for himself or a probability of imminent harm if he… Read more

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Marathon County v. R.O., 2016AP1898-FT, 2/27/17, District 3 (one-judge decision; ineligible for publication); case activity In 2016 R.O. was detained under § 51.15 after she was evicted and went to a local shelter but wasn’t able to do the paperwork to stay at the shelter. According to the two doctors who examined her while she was… Read more

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Dodge County v. J.T., 2016AP613, District 4, 2/9/17 (one-judge decision; ineligible for publication); case activity The threats J.T. made in a letter provided sufficient evidence to find him dangerous to others under § 51.30(1)(a)2.b. J.T. was committed under ch. 51 after he emailed a letter to various people saying Governor Scott Walker has to be… Read more

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Iowa County v. J.L.R., 2016AP1459, 1/12/17 (one-judge decision; ineligible for publication); case activity (including briefs) J.L.R. challenges her ch. 51 commitment on the ground that there was insufficient evidence that she was dangerous to herself or others. The court of appeals finds sufficient evidence as to danger to others, and so affirms.  J.L.R. apparently told… Read more

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