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A. Ch. 51, Mental health

Dane County v. T.B., 2015AP799. 10/1/15, District 4 (1-judge opinion, ineligible for publication); case activity T.B. sought to vacate an order for a Chapter 51 commitment on the grounds that the circuit court lost competency to proceed when it failed to make a verbatim record of his probable cause hearing per Wis. Stat. §51.20(5). According to… Read more

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Evidence sufficient to support Ch. 51 commitment

Kenosha County v. CMM, 2015AP504, 9/23/15, District 2 (1-judge opinion; ineligible for publication); case activity Like many Chapter 51 appeals, this one didn’t challenge any legal standards. It argued that the evidence in this particular case did not meet the test for “dangerousness” in §51.20(1)(a)2.d. The court of appeals found the evidence more than sufficient. ¶8… Read more

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Ozaukee County v. M.L.G., 2015AP1469-FT, 9/23/15, District 2 (1-judge opinion; ineligible for publication); case activity More specifically, the court of appeals held that the County had offered evidence sufficient to establish that MLG was dangerous under §51.20(1)(a)2.c and that he was substantially incapable of understanding his treatment options under § 51.61(1)(g)4b: [T]he County presented evidence of recent… Read more

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Ozaukee County v. C.Y.K., 2015AP1080-FT, District 2, 9/9/15 (one-judge decision; ineligible for publication); case activity Even though the examining psychiatrist opined that C.Y.K. was not substantially incapable of making an informed choice about accepting or refusing medication or treatment, the record as a whole supported the circuit court’s order for involuntary medication and treatment. C.Y.K. argues… 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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Walworth County DHS v. M.M.L., 2014AP2845, 7/15/15, District 2 (one-judge opinion, ineligible for publication); case activity (including briefs) The court of appeals affirms the involuntary commitment for M.M.L. under § 51.20(1)(a)2.c., which requires evidence of impaired judgment based on recent acts or omissions showing a substantial probability that she would physically impair or injure herself or… Read more

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Dunn County v. Dennis M., 2014AP2579, District 3, 6/16/15 (one-judge decision; ineligible for publication); case activity Despite the fact Dennis M. can’t possess a firearm as a result of a prior involuntary commitment order, his appeal from that order is moot because he entered into a voluntary stipulation to recommitment that has expired and not been renewed. While he was in… 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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