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
e. Dangerousness
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
Trempealeau County v. C.B.O., 2021AP1955 & 2022AP102, 8/30/22, District 3, (1-judge opinion, ineligible for publication); case activity This is a double defense win! You might even call it a quadruple defense win! The court of appeals consolidated “Chris’s” appeals from his initial commitment order and his recommitment order. It reversed his initial commitment order because… Read more
Winnebago County v. D.E.S., 2022AP251, 8/31/22, District 2, (1-judge opinion, ineligible for publication); case activity Langlade County v. D.J.W. requires a circuit to make specific factual findings with reference to the dangerousness standard that its recommitment order is based upon. The circuit court failed to follow D.J.W. but the court of appeals affirmed because the… Read more
Barron County v. K.L., 2021AP133, District 3, 8/9/22 (one-judge decision; ineligible for publication); case activity Langlade County v. D.J.W., 2020 WI 41, ¶3, 391 Wis. 2d 231, 942 N.W.2d 277, held that “going forward circuit courts in recommitment proceedings are to make specific factual findings with reference to the subdivision paragraph of Wis. Stat. §… Read more
Manitowoc County v. J.M.K., 2022AP122, 7/27/22, District 2, (1-judge opinion; ineligible for publication); case activity J.M.K. is currently diagnosed with schizoaffective disorder. He has been committed several times since 2015. Right now he is doing well. He lives in a supervised apartment but holds a job, participates in community activities, and works out at the… Read more
Sauk County v. S.A.M., 2022 WI 46, reversing an unpublished court of appeals opinion, 2019AP1033; case activity Unlike other states, Wisconsin appellate courts have for decades dismissed most appeals from expired ch. 51 orders as moot. As a result, there was been little appellate review of circuit court decisions declaring people mentally ill, committing them… Read more
