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f. 51.20(1)(a)2. Dangerousness

Milwaukee County v. A.J.G., 2021AP1338, 5/3/22, District 1, (1-judge opinion, ineligible for publication); case activity When a circuit court orders a ch. 51 recommitment, it must specify which standard of dangerousness the patient will satisfy if treatment is withdrawn. Langlade County. v. D.J.W., 2020 WI 41, ¶40, 391 Wis. 2d 231, 941 N.W.2d 277. This… Read more

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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

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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

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Ozaukee County v. J.D.A., 2021AP1148, District 2, 12/15/21 (one-judge decision; ineligible for publication); case activity Langlade County v. D.J.W., 2020 WI 41, 391 Wis. 2d 231, 942 N.W.2d 277, requires a circuit court ordering a ch. 51 recommitment petition to make specific factual findings with reference to the relevant subdivision paragraph of § 51.20(1)(a)2. on… Read more

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Portage County v. C.K.S., 2021AP1291-FT, 11/24/21, District 4, (1-judge opinion, ineligible for publication); case activity The circuit court recommitted C.K.S. but apparently neglected to specify the applicable standard(s) of dangerousness. C.K.S. appealed arguing that the court violated D.J.W. and that the county’s evidence of dangerousness was insufficient. The court of appeals declined to address the… Read more

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Outagamie County v. D.G.M., 2020AP967, District 3, 9/21/21 (one-judge decision; ineligible for publication); case activity The evidence at the final hearing on the petition to commit D.G.M. under ch. 51 was sufficient to establish all the statutory elements and D.G.M.’s incompetence to refuse medication. This is a entirely fact-dependent decision holding that the evidence proved… Read more

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Shawano County v. S.L.V., 2021AP223, District 3, 8/17/21 (one-judge decision; ineligible for publication); case activity Langlade County v. D.J.W., 2020 WI 41, 391 Wis. 2d 231, 942 N.W.2d 277, requires a circuit court to make specific fact findings about dangerousness at a ch. 51 commitment hearing. The circuit court didn’t do that in this case… Read more

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Trempealeau County v. B.K., 2020AP1166, District 3, 7/27/21 (one-judge decision; ineligible for publication); case activity B.K. (“Brian”) argues he was denied procedural due process because he was not given particularized notice of which standard of dangerousness the County intended to prove at the final commitment hearing. He also contends the evidence presented at the hearing… Read more

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