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3. Civil Commitments

State v. A.M.N., 2024AP440-CR, 3/4/25, District III (1-judge decision, ineligible for publication); case activity While the State concedes that A.M.N.’s statutory right to appear in person for a competency hearing was violated, COA finds the error harmless and affirms. After “Aiden” was charged with two misdemeanors, the circuit court sua sponte raised the issue of… 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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Waukesha County v. R.D.T., 2024AP1390, 2/12/25, District II (1-judge decision, ineligible for publication); case activity COA dismisses “Rex’s” D.J.W. and sufficiency challenges to his 2023 recommitment and involuntary medication orders as moot. Rex was initially committed in 2021, and recommitted twice more before the recommitment at issue in this appeal. (¶2). The circuit court appointed… Read more

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Dane County v. A.M.M., 2024AP1670, 2/13/25, District IV (1-judge decision, ineligible for publication); case activity “Amanda” challenges the sufficiency of the evidence pertaining to her medication order. The COA calls this a “close case,” but affirms. Amanda stipulated to a ch. 51 commitment during a voluntary admission to a psychiatric hospital. Prior to her admission… Read more

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Racine County v. C.D.B., 2024AP1195, 2/5/25, District II (1-judge decision, ineligible for publication); case activity In “Banks’s” most recent appeal, he once again challenges the sufficiency of the evidence pertaining to his extension and medication orders. Like his last appeal, however, those arguments go nowhere. Less than a year ago, we posted on “Banks’s” challenge… Read more

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Sheboygan County v. N.A.L., 2024AP1195, 2/5/25, District II (1-judge decision, ineligible for publication); petition for review granted 5/21/25 case activity In yet another appeal asking COA to clarify the procedure for accepting a stipulation to a mental commitment, COA refuses N.A.L.’s invitation to issue a precedential opinion and affirms based largely on a prior unpublished decision… Read more

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Trempealeau County v. C.B.O., 2024AP1520-FT, 2/4/25, District III (one-judge decision; ineligible for publication); case activity COA affirms, holding that the evidence of a verbal threat to kill someone, and “Carl’s” actions during a subsequent police chase, were both sufficient to establish dangerousness under Wis. Stat. § 51.20(1)(a)2.b. Carl was emergently detained after police responded to… Read more

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Waupaca County v. A.L.H., 2024AP1526, 1/30/25, District IV (1-judge decision, ineligible for publication); case activity While many litigators may have believed the issue of a remedy for a D.J.W. violation had been clarified by SCOW, COA holds that recent precedent does not preclude a circuit court from making the required findings during postconviction proceedings. This is an… Read more

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