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Milwaukee County v. D.C.B., 2021AP581, 10/12/21, Distract 1 (1-judge opinion, ineligible for publication); case activity Before a circuit court enters an order to recommit a person under Chapter 51, it is supposed to make specific factual findings with reference to the applicable standard of dangerousness in Wis. Stat. §51.20(1)(a)2.  Langlade County v. D.J.W., 2020 WI… Read more

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Outagamie County v. J.J.H., 2021AP244, District 3, 9/14/21 (one-judge decision; ineligible for publication); case activity Though J.J.H.’s primary challenge to the extension of his ch. 51 commitment is about the insufficiency of the evidence to prove dangerousness, the court of appeals (aided by the County’s concession) holds that the circuit court failed to make specific… Read more

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Eau Claire County v. J.M.P., 2020AP2014-FT, 6/22/21, District 3; (1-judge opinion, ineligble for publication); case activity A month ago District 3 reversed the recommitment order in this case because the circuit court had violated Langlade County v. D.J.W. That is, the circuit court ordered a recommitment without making specific factual findings tied to one or… Read more

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Eau claire County v. J.M.P., 2020AP2014, 5/25/21, District 3 (1-judge opinion, ineligible for publication); case activity Last term, SCOW ordered circuit courts deciding recommitment cases to make specific factual findings referencing the standard of dangerousness that supported a person’s recommitment. See Langlade County v. D.J.W., 2020 WI 41, ¶3, 391 Wis. 2d 231, 942 N.W.2d… Read more

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Waukesha County v. J.A.K., 2024AP2535, 6/25/25, District II (ineligible for publication); case activity In yet another Chapter 51 appeal, COA rejects the usual arguments and affirms. Evidence of Dangerousness Following recommitment, “Janice” argues the evidence was insufficient to establish she was dangerous. Although COA’s lengthy statement of facts contains many concerning details about Janice’s historical… Read more

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Fond du Lac County v. D.P.E., 2025AP66-FT, 4/30/25, District II (1-judge decision, ineligible for publication); case activity COA affirms the circuit court’s orders recommitting D.P.E. (referred to as “Donald”) and authorizing the involuntarily administration of medication. Donald argued on appeal that the county did not present sufficient evidence to establish dangerousness and failed to meet… Read more

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Winnebago County v. J.S., 2024AP1333, 3/5/25, District II (1-judge decision, ineligible for publication); case activity In yet another case testing the applicability of SCOW’s D.J.W. mandate, COA finds that the circuit court “barely” satisfied those requirements and affirms. “Jacob” argues that the circuit court failed to make sufficient findings in order to find him dangerous under the… Read more

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Sheboygan County v. L.L., 2024AP1443, 2/26/25, District II (1-judge decision, ineligible for publication); case activity COA confronts the usual challenges to a recommitment order and affirms based on a somewhat novel legal theory–that L.L.’s earlier stipulation to a commitment order undermines her sufficiency challenge to the recommitment. D.J.W. Claim “Lucy” first attacks her recommitment order… Read more

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