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b. Recent acts/threats

Ozaukee County v. R.T.H., 2018AP1317, 2/27/19, District 2, (1-judge opinion, ineligible for publication); case activity; Marathon County v. C.M.L., 2017AP2220, 2/26/19, District 3 (1-judge opinion, ineligible for publication); case activity These two, unrelated decisions highlight a recurring due process violation at Chapter 51 hearings. For an original commitment, the county must prove that the person… Read More

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Marathon County v. D.K., 2017AP2217, 8/7/18, District 3 (1-judge opinion, ineligible for publication); Review granted 7/10/19; case activity “Donald” is the pseudonym the court of appeals opinion assigned to D.K., who was committed under §51.20(a)2.b. Although Dr. Dave, the examining physician, waffled on the odds of whether Donald might do serious physical harm without commitment and… Read More

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Dodge County v. J.T., 2016AP613, District 4, 2/9/17 (one-judge decision; ineligible for publication); case activity The threats J.T. made in a letter provided sufficient evidence to find him dangerous to others under § 51.30(1)(a)2.b. J.T. was committed under ch. 51 after he emailed a letter to various people saying Governor Scott Walker has to be… Read More

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Iowa County v. J.L.R., 2016AP1459, 1/12/17 (one-judge decision; ineligible for publication); case activity (including briefs) J.L.R. challenges her ch. 51 commitment on the ground that there was insufficient evidence that she was dangerous to herself or others. The court of appeals finds sufficient evidence as to danger to others, and so affirms.  J.L.R. apparently told… Read More

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Rock County v. S.J.M., 2016AP255-FT, 5/19/16, District 4 (one-judge opinion; ineligible for publication); case activity A circuit court involuntarily committed S.J.M. under §51.20(1)(a)1 -2 after finding him mentally ill, a proper subject for treatment, and dangerous.  S.J.M. challenged the “dangerous” determination and, specifically, the finding that he threatened his mother with serious physical harm, which… Read More

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Kenosha County v. Steven H., 2014AP1435-FT, District 2, 10/15/14 (1-judge opinion ineligible for publication); case activity The court of appeals here affirmed an order finding Steven H. “dangerous” under §51.20(1)(a)2.b, which requires, among other things, evidence that people were placed in reasonable fear of Steven’s violent behavior. Under this standard, a court may consider threats voiced… Read More

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Outagamie County v. Michael H., 2013AP1638-FT, District 3, 11/26/13 (1-judge decision, ineligible for publication), petition for review granted 6/12/14, affirmed, 2014 WI 127; case activity Michael H. challenges a jury verdict finding him “dangerous” under Wis. Stat. § 51.20(1)(a)2a and involuntarily committing him for mental health treatment.  Given this procedural posture, the court of appeals’ holding seems… Read More

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Milwaukee County v. Cheri V., 2012AP1737, District 1, 12/18/12  court of appeals decision (1-judge, ineligible for publication); case activity   Mental health commitment, § 51.20, requires proof of mental illness and dangerousness. Cheri V. limits this challenge to the latter; the court agrees: ¶7        As seen from our recitation of the facts adduced at the trial… Read More

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