Barron County v. K.L., 2022AP502, District 3, 02/07/2023 (one-judge decision, ineligible for publication), case activity K.L. (Katie) challenged the 2021 extension of her original 2013 Chapter 51 commitment on two grounds: (1) insufficient evidence of dangerousness and (2) the circuit court’s failure to “make specific factual findings with reference to the subdivision paragraph of Wis… Read more
1. Original commitment
Rock Count v. H.V., 2022AP1585-FT, 1/20/23, District 4; (1-judge opinion, ineligible for publication); case activity This is an appeal from a ch. 51 recommitment under the 2nd standard– dangerousness to others. H.V.’s main argument was that the circuit court erroneously relied on hearsay to find that he is dangerous when not committed. The court of… Read more
Waukesha County v. G.M.M., 2022AP1207, 1/18/23, District 2, (1-judge opinion, ineligible for publication); case activity This appeal involves a recommitment under the 3rd standard of dangerousness. G.M.M. argued that the county presented insufficient evidence of both mental illness and dangerousness. She also argued that the circuit court failed to make the findings required under Langlade… Read more
Calumet County DH&HS v. T.M.S., 2022AP1563-FT, 1/11/23; District 2, (1-judge opinion, ineligible for publication); case activity The circuit court recommitted T.M.S. based on the 3rd and 4th standards of dangerousness. On appeal, he challenged the sufficiency of the county’s evidence and underscored Dr. Bales’ admission that he couldn’t point to any specific information in T.M.S.’s… Read more
Marathon County v. L.A.R., 2022AP1226-FT, 12/29/22, District 3 (one-judge opinion; ineligible for publication); case activity “Laura” has suffered from bipolar disorder for over 30 years. At her initial commitment hearing, one examiner testified that she met the 2nd standard of dangerousness. Another testified that she also met the 4th standard. The circuit court held that… Read more
Winnebago County v. C.L.S., 2022AP1155-FT, 12/14/22, District 2, (1-judge opinion, ineligible for publication); case activity C.L.S. sought reversal of his recommitment under §51.20(1)(a)2.e arguing that the county’s evidence of dangerousness was insufficient, and the circuit court failed to make the findings required by Langlade County v. D.J.W., 2020 WI 41, 391 Wis. 2d 231, 942… Read more
Winnebago County v. J.D.J., 2022AP1357-FT, 11/23/22, District 2, (1-judge opinion, ineligible for publication); case activity J.D.J. has schizophrenia. At his recommitment hearing, Dr. Monese testified that if treatment were withdrawn, he would become a proper subject of commitment under §51.20(1)(a)2.c. J.D.J. does not believe he has a mental illness, so he would stop treatment and… Read more
Sauk County v. A.D.S., 2022AP550, 11/17/22, District 4, (1-judge opinion, ineligible for publication); case activity The circuit court recommitted A.D.S. based on §51.20(1)(a)2.c, which seems to be the standard du jour for ch. 51 recommitments. Even though A.D.S. hadn’t recently behaved dangerously, the court of appeals affirmed because recommitments may be based on past evidence… Read more
