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COA holds that evidence was sufficient for extension of underlying 2015 commitment order

Racine County v. P.Z., 2024AP146-FT, 5/1/24, District II (one-judge decision; ineligible for publication); case activity

In a relatively straightforward appeal of a recommitment order, COA rejects P.Z.’s sufficiency challenges and affirms.

“Paul” challenges the evidence used to obtain this recommitment order, arguing that his dated conduct in 2015 does not prove current dangerousness. (¶12). COA holds, however, that the County “sufficiently ‘connected the dots’ between previous dangerous acts and the subject individual’s current situation to satisfy the ‘dangerousness’ requirement for recommitment.” (¶11).

Here, the expert witness gave his expert “prediction” that Paul would become dangerous but-for an extension order and that prediction

is supported by the history of dangerous behavior in Paul’s treatment record (including breaking his brother’s ankle and threatening his mother), Paul’s apparent failure to presently appreciate or have insight into his mental illness, and the high likelihood that Paul would stop taking medication and getting treatment if his commitment were discontinued.

(¶12). Although Paul cites a few recent defense wins in the court of appeals to buttress his arguments, COA finds the cited cases distinguishable. (¶¶13-14). Accordingly, his challenge to the commitment and associated medication order fails.

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