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1. Original commitment

Calumet County DH&HS v. T.M.S., 2022AP1563-FT, 1/11/23; District 2, (1-judge opinion, ineligible for publication); case activity The circuit court recommitted T.M.S. based on the 3rd and 4th standards of dangerousness. On appeal, he challenged the sufficiency of the county’s evidence and underscored Dr. Bales’ admission that he couldn’t point to any specific information in T.M.S.’s… Read more

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Marathon County v. L.A.R., 2022AP1226-FT, 12/29/22, District 3 (one-judge opinion; ineligible for publication); case activity “Laura” has suffered from bipolar disorder for over 30 years. At her initial commitment hearing, one examiner testified that she met the 2nd standard of dangerousness. Another testified that she also met the 4th standard. The circuit court held that… Read more

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Winnebago County v. C.L.S., 2022AP1155-FT, 12/14/22, District 2, (1-judge opinion, ineligible for publication); case activity C.L.S. sought reversal of his recommitment under §51.20(1)(a)2.e arguing that the county’s evidence of dangerousness was insufficient, and the circuit court failed to make the findings required by Langlade County v. D.J.W., 2020 WI 41, 391 Wis. 2d 231, 942… Read more

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Winnebago County v. J.D.J., 2022AP1357-FT, 11/23/22, District 2, (1-judge opinion, ineligible for publication); case activity J.D.J. has schizophrenia. At his recommitment hearing, Dr. Monese testified that if treatment were withdrawn, he would become a proper subject of commitment under §51.20(1)(a)2.c. J.D.J. does not believe he has a mental illness, so he would stop treatment and… Read more

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Another 3rd standard recommitment affirmed

Sauk County v. A.D.S., 2022AP550, 11/17/22, District 4, (1-judge opinion, ineligible for publication); case activity The circuit court recommitted A.D.S. based on §51.20(1)(a)2.c, which seems to be the standard du jour for ch. 51 recommitments.  Even though A.D.S. hadn’t recently behaved dangerously, the court of appeals affirmed because recommitments may be based on past evidence… Read more

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Marathon County v. T.J.M., 2022AP623, 11/8/22, District 3 (1-judge opinion, ineligible for publication); case activity “Trevor” appealed an order recommitting him for 12 months because (1) the circuit court orally failed to indicate a standard of dangeorusness per Langlade County v. D.J.W., 2020 WI 41, 391 Wis. 2d 231, 942 N.W.2d 277, and (2) the… Read more

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Trempealeau County v. C.J., 2022AP286, 10/11/22, District 3 (one judge decision; ineligible for publication) case activity C.J. (“Carter” in the opinion) is diagnosed with paranoid schizophrenia. He was initially committed after an incident in which he drove recklessly with his girlfriend in the car, threatening to kill her and himself along with the president and… Read more

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Waukesha v. L.J.E., 2022AP292, 10/5/22, District 2, (1-judge opinion, ineligible for publication); case activity “Evans”  was diagnosed with bipolar disorder with psychotic features, a condition considered permanent but manageable with medication. When the County sought to commit her under the 5th standard, she argued that it failed to prove that she did not satisfy one… Read more

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