6. Procedures/hearings/evidence

Sheboygan County v. L.L., 2024AP1443, 2/26/25, District II (1-judge decision, ineligible for publication); case activity COA confronts the usual challenges to a recommitment order and affirms based on a somewhat novel legal theory–that L.L.’s earlier stipulation to a commitment order undermines her sufficiency challenge to the recommitment. D.J.W. Claim “Lucy” first attacks her recommitment order… Read more

Waukesha County v. R.D.T., 2024AP1390, 2/12/25, District II (1-judge decision, ineligible for publication); case activity COA dismisses “Rex’s” D.J.W. and sufficiency challenges to his 2023 recommitment and involuntary medication orders as moot. Rex was initially committed in 2021, and recommitted twice more before the recommitment at issue in this appeal. (¶2). The circuit court appointed… Read more

Sheboygan County v. N.A.L., 2024AP1195, 2/5/25, District II (1-judge decision, ineligible for publication); case activity In yet another appeal asking COA to clarify the procedure for accepting a stipulation to a mental commitment, COA refuses N.A.L.’s invitation to issue a precedential opinion and affirms based largely on a prior unpublished decision. “Nathan” appeals orders for… Read more

Waupaca County v. A.L.H., 2024AP1526, 1/30/25, District IV (1-judge decision, ineligible for publication); case activity While many litigators may have believed the issue of a remedy for a D.J.W. violation had been clarified by SCOW, COA holds that recent precedent does not preclude a circuit court from making the required findings during postconviction proceedings. This is an… Read more

Vernon County v. F.W.R., 2024AP203, District IV, 11/6/24 (one-judge decision; ineligible for publication); case activity COA rejects F.W.R.’s challenges to his involuntary commitment order under Wis. Stat. § 51.20 for alcohol dependence, concluding that a person may be involuntarily committed for treatment for alcoholism, the circuit court followed the proper procedures and the county met… Read more

Waukesha County v. M.A.C., 2024 WI 30, 7/5/24, reversing an unpublished court of appeals decision; case activity (including briefs) In a big defense win, 6 justices agree that M.A.C. is entitled to relief, with four justices joining together to dismantle SCOW’s prior decision in S.L.L. with respect to notice and default judgment in Chapter 51 proceedings… Read more

Marathon County v. N.R.P., 2023AP638, 6/11/24, District III (one-judge decision; ineligible for publication); case activity In yet another Chapter 51 reversal, COA finds fault with both the circuit court’s decision to admit and rely on hearsay evidence and its failure to make the required findings. Hearsay Evidence As is common at recommitment proceedings, the County… Read more