On Point: 3. Civil Commitments

Milwaukee County DHHS Aging and Disability Services v. B.C., 2024AP2521, 4/7/26, District I; case activity

Applying its recent decision published decision in Department on Aging v. J.J., COA again holds that the county’s failure to timely file the required petition and report to initiate the annual review does not deprive the circuit court of competency.

Winnebago County v. L.J.F.G., 2025AP2645-FT, 4/8/26, District II (ineligible for publication); case activity

In a rare appeal from an involuntary medication order related to a protective placement order, COA affirms despite some of the County’s missteps.

Fond du Lac County v. S.R.H., 2025AP2727-FT, 3/18/26, District II (ineligible for publication); case activity

“Seth” challenges the 2025 extension of his ch. 51 commitment, contending that Fond du Lac County failed to introduce clear and convincing evidence to support the conclusion that he is dangerous pursuant to either WIS. STAT. § 51.20(1)(a)2.b. or 51.20(1)(am) and that the circuit court therefore erred in entering the extension order on those grounds. COA affirms.

Grant County Dept of Social Services v. D.G.N., 2025AP2382, 2/27/26, District IV (ineligible for publication); case activity

In this appeal limited to the validity of an order for the involuntary administration of psychotropic medication in a guardianship case, COA holds that the county failed to meet two of the Wis. Stat. § 55.14(3) requirements.

State v. J.D.B., 2026 WI , 2/25/26, reversing a published court of appeals opinion; case activity

SCOW reverses the COA, holding , clarifies the standard of review for each of the Sell factors, holds that Green is overruled to the extent that it “require[d] each and every piece of information it lists” and declines to decide several issues.

Department on Aging v. J.J., 2024AP1850, 2/10/26, District I (recommended for publication); case activity

The COA held in a decision recommended for publication that the deadline for counties to file the annual review of a person subject to protective placement is directory and failing to file timely does not deprive the circuit court of competency, while reminding parties that timely annual review remains statutorily and constitutionally required.

Brown County v. M.S., 2025AP1532, 2/3/26, District III (ineligible for publication); case activity

In yet another appeal focusing on Chapter 55’s dangerousness criterion, COA holds that while the County could have done a better job at this hearing, the evidence passes muster on appeal.

Columbia County v. T.R.B., 2025AP1972, 1/8/26, District IV (ineligible for publication); case activity

T.R.B. argues on appeal that the dangerousness evidence at the recommitment hearing was inadmissible hearsay, that the circuit court relied on that inadmissible hearsay in making its factual findings, and that with the hearsay evidence properly excluded, the county did not present sufficient evidence of his dangerousness. COA rejects his challenges, concluding that there was sufficient nonhearsay evidence in the record but looking to testimony from the initial commitment and taking judicial notice of outside facts.

Eau Claire County v. R.B.-K., 2025AP1466, 12/16/25, District III (ineligible for publication); case activity

In a “close case,” the COA affirmed continuing protective placement over a challenge to the sufficiency of the evidence that “Rory” was a danger to himself.

Portage County v. T.W.P., 2025AP1183, 11/26/25, District IV (ineligible for publication); case activity

In a case involving a commitment order originating in “2008 or 2009,” COA finds that the County failed to prove that T.W.P. is currently dangerous and therefore reverses.