Winnebago County v. A.P.D., 2022AP817, District 2, 11/16/22 (1-judge opinion, ineligible for publication); case activity Winnebago County successfully petitioned to recommit A.P.D. under the 5th standard of dangerousness. On appeal, he argued that the county offered insufficient evidence of mental illness and of dangerousness. Although A.P.D. lost, he raised some good points that the court… Read more
A. Ch. 51, Mental health
Sauk County v. A.D.S., 2022AP550, 11/17/22, District 4, (1-judge opinion, ineligible for publication); case activity The circuit court recommitted A.D.S. based on §51.20(1)(a)2.c, which seems to be the standard du jour for ch. 51 recommitments. Even though A.D.S. hadn’t recently behaved dangerously, the court of appeals affirmed because recommitments may be based on past evidence… Read more
Portage County v. A.R.F., 2022AP1262, 11/17/22, District 4 (one-judge decision; ineligible for publication); case activity A.R.F. challenges the extension of her commitment under ch. 51. She argues the circuit court failed to adequately identify and support one of the statutory dangerousness standards, as is required by Langlade Cnty. v. D.J.W., 2020 WI 41, 391 Wis… Read more
Marathon County v. T.J.M., 2022AP623, 11/8/22, District 3 (1-judge opinion, ineligible for publication); case activity “Trevor” appealed an order recommitting him for 12 months because (1) the circuit court orally failed to indicate a standard of dangeorusness per Langlade County v. D.J.W., 2020 WI 41, 391 Wis. 2d 231, 942 N.W.2d 277, and (2) the… Read more
Trempealeau County v. C.J., 2022AP286, 10/11/22, District 3 (one judge decision; ineligible for publication) case activity C.J. (“Carter” in the opinion) is diagnosed with paranoid schizophrenia. He was initially committed after an incident in which he drove recklessly with his girlfriend in the car, threatening to kill her and himself along with the president and… Read more
Waukesha v. L.J.E., 2022AP292, 10/5/22, District 2, (1-judge opinion, ineligible for publication); case activity “Evans” was diagnosed with bipolar disorder with psychotic features, a condition considered permanent but manageable with medication. When the County sought to commit her under the 5th standard, she argued that it failed to prove that she did not satisfy one… Read more
Sheboygan County HSD v. P.W.S., 2022AP426, District 2, 9/28/22 (one-judge decision; ineligible for publication); case activity In this fact-intensive decision (¶¶2-17), the court of appeals rejects P.W.S.’s challenge to the sufficiency of the evidence that there was a substantial probability he was dangerous under § 51.20(1)(a)2.c. ¶22 The court found that P.W.S. was… Read more
Winnebago County v. P.D.G., 2022AP606-FT, 9/7/22, District 2, (1-judge opinion; ineligible for publication); case activity Winnebago County dumped 550 pages of discovery on counsel 2 hours and 15 minutes before “Paul’s” recommitment hearing, so he requested a adjournment. “Denied!” said the circuit court because §51.20(10)(e) allows only 1 adjournment, which had already been used. If… Read more
