Outagamie County v. Lorna G., 2011AP1662, District 3, 10/25/11 court of appeals decision (1-judge, not for publication); for Lorna G.: Eileen A. Hirsch, SPD, Madison Appellate; case activity Although the trial court’s reference to “potential” for harm was an “imprecise summary”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
1. Original commitment
Outagamie County v. Paul S., 2011AP920, District 3, 9/27/11 court of appeals decision (1-judge, not for publication); for Paul S.: Shelley Fite, SPD, Madison Appellate; case activity ¶9 Wisconsin Stat. § 51.15(5) provides an individual may “not be detained by the law enforcement officer or other person and the facility for more than a total of 72 hours… Read more
Fond du Lac County v. Helen E. F., 2011 WI App 72(recommended for publication), affirmed 2012 WI 50; for Helen E.F.: Donald T. Lang, SPD, Madison Appellate; case activity Alzheimer’s disease is not a qualifying mental condition for purposes of ch. 51 commitment, therefore Helen E.F. is not a proper subject for treatment as a… Read more
Brown County v. Quinn M., 2010AP3162, District 3, 4/26/11 court of appeals decision (1-judge, not for publication); for Quinn M.: Chandra N. Harvey, SPD, Madison Appellate; case activity Evidence held sufficient to support extension of ch. 51 commitment upheld. 1. Mental illness. Expert testified that she was certain Quinn had a mental illness, though given… 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Barron County v. Dennis H., 2010AP1026, District 3, 10/19/10 court of appeals decision (1-judge, not for publication); for Dennis H.: Jefren E. Olsen, SPD, Madison Appellate Evidence held sufficient to support finding of dangerousness. 1) Recent overt act, attempt or threat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
Milwaukee County v. Earl Z., 2010AP704, District 1, 9/23/10 court of appeals decision (1-judge, not for publication); for Earl Z.: Jeremy Perri, SPD, Milwaukee Appellate County appeal of dismissal of emergency detention at probable cause stage is moot, where facts supporting that requested detention are no longer operative. Exceptions to mootness — appellate court may reach merits if the… Read more
Manitowoc Co. HSD v. Tammy L.C., No. 2010AP118, District II, 7/14/10 court of appeals decision (1-judge, not for publication); for Tammy L.C.: Matthew S. Pinix Mootness – Discharge from Civil Commitment Appeal of commitment order is dismissed as moot where appellant has been discharged and no extension sought. Mootness raises a question of policy, not jurisdiction… Read more
Dane County v. Stevenson L.J., 2009 WI App 84 For Stevenson L.J.: Ruth N. Westmont Issue/Holding: Where Stevenson L.J. was detained on an “emergency statement” in one county (Brown), then transferred to another (Dane) before a probable cause hearing, a new emergency statement in Dane County did not establish a new 72-hour time limit for a… Read more
