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2. Recommitment

Review of an unpublished court of appeals opinion; case activity Issue (composed by On Point) Fond du Lac County v. Helen E.F., 2012 WI 50, 340 Wis. 2d 500, 814 N.W.2d 179 held that an individual is capable of rehabilitation, and thus a proper subject for treatment under Chapter 51, when treatment would control the… Read more

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Waukesha County v. J.W.J., 2016AP46-FT, 5/4/16 (1-judge opinion, ineligible for publication),petition for review granted 9/13/16, affirmed, 2017 WI 57; case activity To commit a person involuntarily, the county must show that the person is mentally ill and dangerous. To extend the commitment, the county may prove “dangerousness” by showing that “there is a substantial likelihood, based on… Read more

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Milwaukee County v. Kent F., 2015AP388, District 1, 8/18/15 (one-judge decision; ineligible for publication); case activity The court of appeals rejects Kent’s argument that, under Fond du Lac County v. Helen E.F., 2012 WI 50, 340 Wis. 2d 500, 814 N.W.2d 179, he is not a proper subject for ch. 51 commitment because he is not… Read more

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Kenosha County v. James H., 2014AP2945, 6/3/15, District 2 (1-judge opinion, ineligible for publication); click here for case activity James was diagnosed with chronic paranoid schizophrenia and hospitalized many times. He appeal an order extending his involuntary commitment and argued, unsuccessfully, that the county failed to present evidence of recent acts of violence against others… Read more

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Dane County v. Thomas F.W., 2014AP2469, District 4, 4/23/15 (one-judge decision; ineligible for publication); case activity To extend a ch. 51 commitment, the County must prove the subject individual is a proper subject for treatment, which means showing he or she is “capable of rehabilitation,” §§ 51.01(17) and 51.20(1)(a)1. The court of appeals rejects Thomas’s… Read more

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Dane County v. P.H., 2014AP1469, District 4, 3/12/15 (one-judge decision; ineligible for publication); case activity Rejecting P.H.’s claim that the experts who testified based their opinions on “dated” information, the court of appeals finds the evidence was sufficient to extend P.H.’s ch. 51 commitment. P.H. conceded she suffers from a mental illness and is a proper subject… Read more

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Milwaukee County v. Aaron B., 2014AP2008-FT, 2/18/15, District 1 (1-judge opinion; ineligible for publication); case activity Aaron was deemed mentally ill and committed for 2 months under Chapter 51 when he bit off his caregiver’s ear. Afterwards, the county asked to extend his commitment under §51.20(13(g). Based upon statements from Aaron’s treating psychologists, the circuit court… Read more

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Marathon County v. Zachary W., 2014AP955, District 3, 12/2/14 (1-judge decision; ineligible for publication); case activity Even if the circuit court erred it provided multiple definitions of the term “drug” when instructing the jury hearing a ch. 51 commitment case. The County sought to commit Zachary under ch. 51 on the ground that he was drug dependent, § 51.20(1)(a)1., based on… Read more

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