1. Original commitment

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

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

Winnebago County v. Christopher S., 2016 WI 1, on certification from the court of appeals, and affirming the circuit court’s orders for commitment and involuntary medication; majority opinion by Justice Gableman, concurrence/dissent by Justice Abrahamson; case activity The provisions of ch. 51 allowing the involuntary mental health commitment of prison inmates without a finding of dangerousness… Read more

Dane County v. T.B., 2015AP799. 10/1/15, District 4 (1-judge opinion, ineligible for publication); case activity T.B. sought to vacate an order for a Chapter 51 commitment on the grounds that the circuit court lost competency to proceed when it failed to make a verbatim record of his probable cause hearing per Wis. Stat. §51.20(5). According to… 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