Rock County v. S.J.M., 2016AP255-FT, 5/19/16, District 4 (one-judge opinion; ineligible for publication); case activity A circuit court involuntarily committed S.J.M. under §51.20(1)(a)1 -2 after finding him mentally ill, a proper subject for treatment, and dangerous. S.J.M. challenged the “dangerous” determination and, specifically, the finding that he threatened his mother with serious physical harm, which… Read more
f. 51.20(1)(a)2. Dangerousness
Outagamie County v. Adam B., 2015AP718, 4/12/16, District 3 (1-judge opinion; ineligible for publication); case activity (including briefs) The circuit court neglected to specify which of the 5 statutory “dangerousness” standards in §51.20(1)(a)2.a-e supported the Ch. 51 commitment of Adam B. But that did not trouble the court of appeals. Given the “de novo” standard of… Read more
Kenosha County v. CMM, 2015AP504, 9/23/15, District 2 (1-judge opinion; ineligible for publication); case activity Like many Chapter 51 appeals, this one didn’t challenge any legal standards. It argued that the evidence in this particular case did not meet the test for “dangerousness” in §51.20(1)(a)2.d. The court of appeals found the evidence more than sufficient. ¶8… Read more
Ozaukee County v. M.L.G., 2015AP1469-FT, 9/23/15, District 2 (1-judge opinion; ineligible for publication); case activity More specifically, the court of appeals held that the County had offered evidence sufficient to establish that MLG was dangerous under §51.20(1)(a)2.c and that he was substantially incapable of understanding his treatment options under § 51.61(1)(g)4b: [T]he County presented evidence of recent… Read more
Walworth County DHS v. M.M.L., 2014AP2845, 7/15/15, District 2 (one-judge opinion, ineligible for publication); case activity (including briefs) The court of appeals affirms the involuntary commitment for M.M.L. under § 51.20(1)(a)2.c., which requires evidence of impaired judgment based on recent acts or omissions showing a substantial probability that she would physically impair or injure herself or… Read more
Rock County v. J.N.B., 2014AP774, District 4, 3/26/16 (one-judge decision; ineligible for publication); case activity Having rejected the no merit report filed by J.N.B.’s appellate counsel and ordered counsel to brief the issue of the sufficiency of the evidence, the court of appeals declares “the County presented ample evidence demonstrating that J.N.B. is dangerous because… Read more
Outagamie County v. Lori D., 2014AP1911, District 3, 1/27/15 (1-judge decision; ineligible for publication); case activity There was sufficient evidence to commit Lori under § 51.20(1)(a)2.c. because her behavior over one night showed a “pattern of recent acts or omissions” that evidenced impaired judgment and because the lack of services available in the community established a… Read more
Milwaukee County v. Andy S., 2014AP1885, District 1, 1/13/15 (1-judge decision; ineligible for publication); case activity The evidence was sufficient to prove dangerousness under § 51.20(1)(a)2.a., as it showed Andy “[e]vidence[d] a substantial probability of physical harm to himself … as manifested by evidence of recent threats of or attempts at suicide or serious bodily harm.” ¶14 Andy S. does… Read more
