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mental commitment, COA refuses N.A.L.’s invitation to issue a precedential opinion and affirms based largely on a prior unpublished decision.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
3. Civil Commitments
Trempealeau County v. C.B.O., 2024AP1520-FT, 2/4/25, District III (one-judge decision; ineligible for publication); case activity COA affirms, holding that the evidence of a verbal threat to kill someone, and “Carl’s” actions during a subsequent police chase, were both sufficient to establish dangerousness under Wis. Stat. § 51.20(1)(a)2.b. Carl was emergently detained after police responded to… 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
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
Monroe County v. H.K.B., 2024AP1305, District 4, 1/16/25 (one-judge decision; ineligible for publication); case activity On appeal from the two most recent Watts review hearings, the COA concludes that there was insufficient evidence for the protective placement order because the County failed to prove that H.K.B. was “so totally incapable of providing for . … Read more
Wood County v. P.J.L., 2024AP2098-FT, 1/9/25, District IV (one-judge decision; ineligible for publication); case activity In a chapter 55 appeal arising from a somewhat unusual posture–a continued protective placement order following a jury trial–COA’s invocation of an exceedingly deferential standard of review results in affirmance. P.J.L. has been under a protective placement since 2021. (¶5)… 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
