e. Dangerousness

Portage County v. L.E., 2020Ap1239-FT, District 4, 10/29/20 (one-judge decision; ineligible for publication); case activity The evidence presented at L.E.’s ch. 51 extenstion hearing was sufficient to prove she was dangerous and was not competent to refuse medication. ¶21     …. [Doctor] Khalil’s testimony was not so vague, equivocal, or lacking [as to fail… Read more

Portage County v. E.R.R., 2020AP870-FT, District 4, 10/1/20 (one-judge decision; ineligible for publication); case activity As the supreme court recently emphasized, at a proceeding to extend a ch. 51 commitment, proving dangerousness under § 51.20(1)(am) requires evidence establishing that the person is likely to be dangerous under one of the specific standards in § 51.20(1)(a)2… Read more

Waupaca County v. K.E.K., 2018AP1887, petition for review of an unpublished court of appeals decision granted 7/24/20; case activity Issues presented: Did the circuit court lose competency to conduct a recommitment hearing because the County did not file the evaluation of K.E.K. at least 21 days before the expiration of her commitment, as required by… Read more

Fond du Lac County v. S.N.W., 2020AP274-FT, District 2, 7/15/20 (one-judge decision; ineligible for publication), petition  for review granted 11/19/20; case activity The testimony of the county’s expert provided sufficient evidence of dangerousness under § 51.20(1)(a)2.b. and (1)(am). ¶9     The evidence in the record before us establishes that S.N.W. has a history of “singling… Read more

Winnebago County v. S.H., 2020 WI App 46; case activity The court of appeals rarely publishes opinions in “fast track” cases. It took that unusual step here. The opinion strives to show the type of evidence that is sufficient for a recommitment even though the mentally ill person has taken all of her medication and… Read more

Winnebago County v. L. F.-G., 2019AP2010, 5/20/20, District 2 (one-judge decision; ineligible for publication); case activity This is an appeal of the extension of the commitment of someone the court calls “Emily.” Following our supreme court’s decision in Portage County v. J.W.K., 2019 WI 54, ¶19, 386 Wis. 2d 672, 927 N.W.2d 509, the court… Read more

Langlade County v. D.J.W., 2020 WI 41, reversing an unpublished court of appeals opinion, 4/24/20; case activity Wisconsin’s involuntary commitment rate is higher than that of any other state–by a long shot. According to a report for the Substance Abuse and Mental Health Services, the annual commitment rate among states ranges from 0.23 to 43.8… Read more