Milwaukee County v. Andy S., 2014AP1885, District 1, 1/13/15 (1-judge decision; ineligible for publication); case activity The evidence was sufficient to prove dangerousness under § 51.20(1)(a)2.a., as it showed Andy “[e]vidence[d] a substantial probability of physical harm to himself … as manifested by evidence of recent threats of or attempts at suicide or serious bodily harm.” ¶14 Andy S. does… Read more
f. 51.20(1)(a)2. Dangerousness
Outagamie v. Michael H., 2014 WI 127, 12/16/14, affirming an unpublished court of appeals decision, majority opinion by Justice Crooks; case activity Section 51.20(1)(a)2.a authorizes the involuntary commitment of a person who is “dangerous,” a test that may be met by showing recent threats of, or attempts at, suicide. This unanimous decision holds that in… Read more
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
Winnebago County v. William A.M., 2014AP977-FT, District 2, 9/10/14 (1-judge; ineligible for publication); case activity The evidence at trial was sufficient to prove William was dangerous under § 51.20(1)(a)2.c., which requires a showing of “such impaired judgment, manifested by evidence of a pattern of recent acts or omissions, that there is a substantial probability of physical impairment… Read more
On review of an unpublished court of appeals decision; case activity Issue (composed by On Point) Was there sufficient evidence to establish Michael H. was “dangerous” under § 51.20(1)(a)2.a. or c., based either on his “threats” of suicide or a pattern of acts or omissions showing such impaired judgment that there is a substantial probability… Read more
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
Winnebago County v. Gina A.R., 2013AP226, District 2, 5/22/13; court of appeals decision (1-judge; ineligible for publication); case activty The court rejects Gina A.R.’s claim that the evidence at the final hearing was insufficient to show she is mentally ill, a proper subject for treatment, and dangerous, noting that much of her argument discusses facts… Read more
Review of unpublished court of appeals decision; case activity Issues (composed by On Point) 1. Whether there was sufficient proof that Mary F.-R. evidenced a “substantial probability of physical harm” to herself or others and was therefore dangerous under Wis. Stat. § 51.20(1)(a)(2). 2. Whether Wis. Stat. § 51.20(11) is an unconstitutional violation of equal… Read more
