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
e. Dangerousness
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
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 Monese testified that if treatment were withdrawn, he would become a proper subject of commitment under §51.20(1)(a)2.c. J.D.J. does not believe he has a mental illness, so he would stop treatment and… Read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
Winnebago County v. A.P.D., 2022AP817, District 2, 11/16/22 (1-judge opinion, ineligible for publication); case activity Winnebago County successfully petitioned to recommit A.P.D. under the 5th standard of dangerousness. On appeal, he argued that the county offered insufficient evidence of mental illness and of dangerousness. Although A.P.D. lost, he raised some good points that the court… Read more
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
Portage County v. A.R.F., 2022AP1262, 11/17/22, District 4 (one-judge decision; ineligible for publication); case activity A.R.F. challenges the extension of her commitment under ch. 51. She argues the circuit court failed to adequately identify and support one of the statutory dangerousness standards, as is required by Langlade Cnty. v. D.J.W., 2020 WI 41, 391 Wis… Read more
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
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
