1. Original commitment

Walworth County v. P.S., 2021AP2090-FT, 4/13/22, District 2, (1-judge opinion, ineligible for publication); case activity The circuit court entered an initial commitment order against P.C. without specifying a standard of dangerousness. The court of appeals shrugged. It did not matter because the circuit court’s findings “were specific, tracked the statutory criteria, and are supported by… Read more

Waupaca County v. H.I.B., 2021AP2026, 4/7/22, District 4 (1-judge opinion ineligible for publication); case activity It is uncontested that “Hazel” has done well for three commitments in a row. Yet the court of appeals has affirmed her 4th Chapter 51 recommitment  because the jury could have inferred a “substantial probability” of death or serious injury… Read more

Ozaukee County v. J.D.A., 2021AP1148, District 2, 12/15/21 (one-judge decision; ineligible for publication); case activity Langlade County v. D.J.W., 2020 WI 41, 391 Wis. 2d 231, 942 N.W.2d 277, requires a circuit court ordering a ch. 51 recommitment petition to make specific factual findings with reference to the relevant subdivision paragraph of § 51.20(1)(a)2. on… Read more

Portage County v. C.K.S., 2021AP1291-FT, 11/24/21, District 4, (1-judge opinion, ineligible for publication); case activity The circuit court recommitted C.K.S. but apparently neglected to specify the applicable standard(s) of dangerousness. C.K.S. appealed arguing that the court violated D.J.W. and that the county’s evidence of dangerousness was insufficient. The court of appeals declined to address the… Read more

Waukesha County v. E.J.W., 2021 WI 85, 11/23/21, reversing an unpublished court of appeals’ opinion; case activity This 4-3 “defense win” delivers a 1-2-3 punch! The decision:  (1) holds that a person undergoing commitment has the right to demand a jury 48 hours before the time set for his final hearing–even if the hearing is… Read more

Outagamie County v. D.G.M., 2020AP967, District 3, 9/21/21 (one-judge decision; ineligible for publication); case activity The evidence at the final hearing on the petition to commit D.G.M. under ch. 51 was sufficient to establish all the statutory elements and D.G.M.’s incompetence to refuse medication. This is a entirely fact-dependent decision holding that the evidence proved… Read more

Shawano County v. S.L.V., 2021AP223, District 3, 8/17/21 (one-judge decision; ineligible for publication); case activity Langlade County v. D.J.W., 2020 WI 41, 391 Wis. 2d 231, 942 N.W.2d 277, requires a circuit court to make specific fact findings about dangerousness at a ch. 51 commitment hearing. The circuit court didn’t do that in this case… Read more