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
1. Original commitment
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
Winnebago County v. J.C.S., 2021AP354, District 2, 8/4/21 (one-judge decision; ineligible for publication); case activity The evidence presented at J.C.S.’s final commitment hearing was “just enough” to prove J.C.S. was a proper subject of treatment, one of the elements necessary to justify a ch. 51 commitment order, § 51.20(1)(a)1. For purposes of ch. 51, “treatment”… Read more
Waukesha County v. M.J.S., 20221AP105-FT, District 2, 7/28/21 (one-judge decision; ineligible for publication); case activity Under § 51.20(11)(a), a demand for a jury trial must be made “48 hours in advance of the time set for final hearing,” if notice of final hearing was provided to the subject individual or his or her lawyer. Applying… Read more
Trempealeau County v. B.K., 2020AP1166, District 3, 7/27/21 (one-judge decision; ineligible for publication); case activity B.K. (“Brian”) argues he was denied procedural due process because he was not given particularized notice of which standard of dangerousness the County intended to prove at the final commitment hearing. He also contends the evidence presented at the hearing… Read more
Outagamie County DHHS v. M.D.H., 2020AP86, District 3, 7/13/21 (one-judge decision; ineligible for publication); case activity The evidence at M.D.H.’s final commitment hearing proved he was dangerous under § 51.20(1)(a)2.d. Under that statute, an individual is dangerous if he or she has engaged in recent acts or omissions that show that, because of mental illness, he… Read more
Marathon County v. T.A.T., 2019AP1709, District 3, 6/29/21 (one-judge decision; ineligible for publication); case activity The testimony of the the three witnesses called by the County provided sufficient evidence to support the court’s finding that T.A.T. (“Travis”) was dangerous under § 51.20(1)(a)2.a. Travis was emergently detained after he was found on the ground near a… Read more
Outagamie County v. X.Z.B., 2020AP2058, 6/22/2121, District 3, (1 judge opinion, ineligible for publication); case activity This case involves the recommitment of a protectively placed person based on §51.20(1)(a)2.c., the 3rd standard of dangerousness. The court of appeals reversed the circuit courts’ recommitment order for insufficient evidence. And, for the second time in one week… Read more
