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
A. Ch. 51, Mental health
Price County v. C.N.S., 2024AP853, District III, 1/22/25 (one-judge decision; ineligible for publication); case activity Appellant CNS wins a battle but loses the war as the COA affirms the circuit court’s order extending her commitment under Ch. 51, but reverses order authorizing involuntary medication. The Court clarified that a circuit court meets D.J.W.’s requirement to… Read more
Outagamie County v. M.J.B., 2024AP250, 2/11/25, District III (recommended for publication); case activity In a case clarifying a legal question that has persisted for years in 51 litigation, COA holds that when the examiners do not satisfy the statutorily-imposed deadline for filing their reports in connection with a final hearing in an original commitment proceeding… Read more
Dane County v. M.A.A., 2024AP1589, 12/27/24, District IV (one-judge decision; ineligible for publication); case activity The Court of Appeals affirmed the circuit court’s order authorizing involuntarily administering medication to M.A.A. in light of evidence that M.A.A. denies he has a mental illness. M.A.A. was committed under Chapter 51 due to a history of schizophrenia spectrum… Read more
Monroe County v. M.C., 2024AP924, 12/12/24, District IV (one-judge decision; ineligible for publication); case activity The Court of Appeals reversed the circuit court’s commitment order under Chapter 51 where the court did not make sufficient factual findings to support its conclusion that M.C. was dangerous, as required by D.J.W. Police issued a statement of emergency… Read more
Trempealeau County v. R.B., 2024AP1052, 12/10/24, District III (one-judge decision; ineligible for publication); case activity COA affirms, holding that the evidence of potential deterioration during commitment period justified extension order. “Rachel” was originally committed in July of 2023 due to concerns that she would harm herself given that she was hearing voices telling her kill… 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.D.S., Jr., 2024AP1315, District II, 11/6/24 (one-judge decision; ineligible for publication); case activity COA rejects “Smith’s” challenges raising commonly-litigated appellate issues and affirms in this chapter 51 case, concluding that the circuit court applied the correct legal standard and the county met its burden to show that Smith was dangerous under sub… Read more
