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3. Civil Commitments

Winnebago County v. T.M.G., 2023AP681, 1/24/24, District II (one-judge decision; ineligible for publication); case activity Despite T.M.G.’s challenges, COA affirms this extension and related medication order applying what it believes to be well-settled precedent. “Thomas” challenges an order extending his commitment finding him dangerous under § 51.20(1)(a)2.b.  (¶1). He argues that the County failed to… Read more

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Douglas County v. M.L, 2022AP141, 12/28/23, District III (one-judge decision; ineligible for publication); case activity Faced with a challenge to the circuit court’s competency in this protective placement appeal, COA holds that the appellant has forfeited his challenge and therefore affirms. “Mason” appeals an order continuing his protective placement following a due process review hearing… Read more

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Ozaukee County D.H.S. v. M.A.G., 2023AP681, 11/29/23, District II (one-judge decision; ineligible for publication); case activity M.A.G. challenged the extension of her Chapter 51 commitment and the order finding her incompetent to refuse medication. The court of appeals affirms both orders after concluding that the county presented sufficient evidence of dangerousness under the the third… Read more

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  Douglas County v. J.M., 2022AP2035, 11/28/23, District 3 (one-judge decision; ineligible for publication); case activity “James” was subjected to a guardianship under ch. 54 and a protective placement under ch. 55 in 2020. He had annual reviews of placement in 2021 and 2022; the last one is the subject of this appeal. James argues… Read more

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Winnebago County v. A.P.D., 2023AP863, 12/13/23, District II (one-judge decision; ineligible for publication); case activity In yet another defense win reliant on Langlade County v. D.J.W.,  COA holds that the circuit court failed to make adequate findings in this Chapter 51 appeal. “Andrew” challenges a recommitment order based on the fifth standard. (¶3). He argues that… Read more

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Winnebago County v. D.E.W., 2023AP215, petition for review of an unpublished court of appeals decision granted 12/11/23; dismissed as improvidently granted 5/14/24, case activity (including briefs) SCOW accepts a case poised to resolve ongoing conflict in COA with respect to involuntary medication orders in Chapter 51 appeals. As we discussed in our post on this… Read more

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Racine County v. B.L.M., 2023AP757, 11/22/23, District II (ineligible for publication); case activity Despite a creative challenge to a continued protective placement order, COA rejects any argument that the circuit court lost competency by failing to timely reappoint a GAL in this protective placement appeal. § 55.18 lists the required procedures for an annual review… Read more

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Graham L. Stowe v. Gregory Van Rybroek, 18-CV-400-wmc (W.D. Wis. 11/6/23). Having recently prevailed on a judicial bias claim in state court, Stowe makes a return appearance to the blog on his 2018 federal habeas petition. Unfortunately, the Western District of Wisconsin denied the petition, which had been pending for close 5 years. The petition… Read more

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