Rock County v. J.B., 2021AP1157 & 2021AP1883, 4/14/22, District 4 (one-judge decision; ineligible for publication); case history This is a consolidated appeal of J.B.’s original, six-month commitment and a subsequent nine-month extension of that commitment. J.B. was detained after his father reported that he’d not had anything to eat or drink for four days. He… Read more
3. Civil Commitments
Walworth County v. P.S., 2021AP2090-FT, 4/13/22, District 2, (1-judge opinion, ineligible for publication); case activity The circuit court entered an initial commitment order against P.C. without specifying a standard of dangerousness. The court of appeals shrugged. It did not matter because the circuit court’s findings “were specific, tracked the statutory criteria, and are supported by… Read more
Waupaca County v. H.I.B., 2021AP2026, 4/7/22, District 4 (1-judge opinion ineligible for publication); case activity It is uncontested that “Hazel” has done well for three commitments in a row. Yet the court of appeals has affirmed her 4th Chapter 51 recommitment because the jury could have inferred a “substantial probability” of death or serious injury… Read more
State v. Christopher W. Yakich, 2022 WI 8, 2/16/22, affirming an unpublished court of appeals decision; case activity (including briefs) When a defendant is found not guilty by reason of mental disease or defect (NGI) for more than one offense, the commitments for the offenses may be ordered to run consecutively. As we explained in… Read more
Taylor County Human Services v. L.E., 2021AP1292, 2/15/22, District 3, (1-judge opinion, ineligible for publication); case activity A circuit court extended “Luca’s” commitment, directed that he be placed in a locked ward, and ordered involuntary medication. On appeal, Luca challenges his placement in a locked ward and the involuntary medication order. At a minimum, the… Read more
Portage County v. K.K., 2021AP1315, 2/10/22, District 4, (1-judge opinion, ineligible for publication); case activity This opinion has alarming implications for disabled people. The circuit court issued a summary judgment order continuing K.K.’s protective placement. She appealed and argued that summary judgment is not allowed in Chapter 55 cases. The court of appeals refused to… Read more
Outagamie County v. D.D.G., 2021AP511, District 3, 1/20/22, (1-judge opinion, ineligible for publication); case activity “Dana” has been under commitment since 2017. It is undisputed that she has taken her medication and has done nothing dangerous in the interim. Yet the court of appeals affirmed her 2021 recommitment because she questions her diagnosis and her… Read more
Rock County v. H.V., 2021AP1760-FT, 1/13/22, District 4 (1-judge opinion, ineligible for publication); case activity This appeal concerns a recurring problem in Chapter 51 cases: the lack of objection to damaging hearsay at the final hearing. If the appellate lawyer raises ineffective assistance of counsel in the circuit court, the case will become moot before… Read more
