COA affirms extending involuntary commitment based on history of not taking medication and suicidal ideation.
Walworth County v. D.J.F., 2025AP2522, 5/6/26, District II (ineligible for publication); case activity
The COA affirmed the circuit court’s order extending D.J.F.’s involuntary commitment because there was a substantial likelihood he would be a proper subject for commitment if treatment were withdrawn given his history of not taking medication for schizoaffective disorder unless court ordered.
A psychiatrist testified at the extension hearing that D.J.F. suffers from schizoaffective disorder, does not believe he is mentally ill, and will not take medication unless court ordered. (¶ 3). The psychiatrist said D.J.F. becomes paranoid and delusional when he is not medicated. She determined D.J.F. would be a proper subject for commitment if treatment were withdrawn and noted he had been recommitted after two previous commitments. The psychiatrist thought D.J.F. would also be a danger to himself if treatment were withdrawn in light of a prior attempted suicide. (¶ 4).
D.J.F.’s mother testified that his current commitment arose after he had been hospitalized for six weeks because he stopped drinking any fluids and suffered damage to his kidney. While he was hospitalized, his mother said, D.J.F. told her he was going to kill her. (¶¶ 6-7). The circuit court extended D.J.F.’s commitment because he was a danger to himself or others.
The COA rejected D.J.F.’s argument that the circuit court’s order was not supported by sufficient evidence. The Court noted that, for a recommitment, the County may meet its burden to prove dangerousness by establishing there is a substantial likelihood that the person would be a proper subject for commitment if treatment were withdrawn. (¶ 14). The COA found a substantial likelihood given D.J.F.’s history of refusing to take medication if not court ordered and subsequently decompensating. The COA observed that D.J.F. has a history of suicidal ideation and was not taking his medication before he was hospitalized for kidney malfunction. (¶ 15).