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1. Original commitment

Kenosha County v. Steven H., 2014AP1435-FT, District 2, 10/15/14 (1-judge opinion ineligible for publication); case activity The court of appeals here affirmed an order finding Steven H. “dangerous” under §51.20(1)(a)2.b, which requires, among other things, evidence that people were placed in reasonable fear of Steven’s violent behavior. Under this standard, a court may consider threats voiced… Read more

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Winnebago County v. William A.M., 2014AP977-FT, District 2, 9/10/14 (1-judge; ineligible for publication); case activity The evidence at trial was sufficient to prove William was dangerous under § 51.20(1)(a)2.c., which requires a showing of “such impaired judgment, manifested by evidence of a pattern of recent acts or omissions, that there is a substantial probability of physical impairment… Read more

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Waukesha County v. Steven R.C., 2014AP1032-FT, District 2, 9/10/14 (1-judge; ineligible for publication); case activity The failure to hold a probable cause hearing within 72 hours of Steven’s initial detention deprived the circuit court of competency to proceed, despite the County’s filing of a new petition within the 72-hour time period with new allegations. Steven was detained… Read more

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Ch. 51 appeal is moot

Milwaukee County v. Rebecca G., 2014AP359, District 1, 9/3/14 (1-judge; ineligible for publication); case activity Rebecca’s appeal of her ch. 51 commitment is dismissed as moot because the six-month commitment order expired while the appeal was pending and the County didn’t seek an extension. A court may decide a case even though it’s moot if: the issue presented is of… Read more

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Ozaukee County v. Mark T.J., 2014AP479, District 2, 8/27/14 (1-judge; ineligible for publication); case activity The failure to hold an initial hearing within 72 hours of Mark’s arrival at the hospital where he was detained deprived the circuit court of competency to order an initial commitment order under ch. 51. But his appeal from that… Read more

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On review of an unpublished court of appeals decision; case activity Issue (composed by On Point) Was there sufficient evidence to establish Michael H. was “dangerous” under §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

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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

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Milwaukee County v. Mary F.-R., 2012AP958, affirming an unpublished court of appeals opinion; case activity Majority opinion by Justice Crooks; concurrence by Chief Justice Abrahamson; additional concurrence by Justice Ziegler (joined by Justices Roggensack and Gableman) The issues in this case spring from State v. Post, 197 Wis. 2d 279, 318-319, 541 N.W.2d 115 (1995)(“persons committed under… Read more

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