On Point: C. Ch. 55, Protective placement

Milwaukee County Department on Aging v. J.J., 2024AP1850, petition for review of a published court of appeals decision, granted 10/14/26; case activity

SCOW will decide whether the circuit court loses competency to continue protective placement when the County does not comply with the deadline to file a petition and report for annual review.

Calumet County v. S.A., 2026AP1076, 10/7/26, District II (ineligible for publication); case activity

COA reverses S.A.’s protective placement, concluding that the county failed to present sufficient evidence that her incapacity is a result of developmental disability, degenerative brain disorder,
serious and persistent mental illness, or other like incapacities.

Door County v. R.A.W., 2026AP83, 8/18/26, District III (ineligible for publication); case activity

The COA affirmed the appellant’s protective placement in a 24-hour community based residential facility because evidence from the initial hearing and hearing to continue protective placement was sufficient to show that the current placement was the least restrictive in light of the appellant’s need for medication management and 24-hour supervision.

Racine County v. R.P.L., 2026 WI 26, 7/7/26, affirming an unpublished decision of the court of appeals; case activity

SCOW holds that this appeal from an annual review of a protective placement is not moot, somewhat reluctantly applies the governing standard of review, and affirms.

La Crosse County v. P.A.E., 2025AP303, 6/18/26, District IV (ineligible for publication); case activity

COA reverses the circuit court’s order continuing PAE’s protective placement on the basis that La Crosse County failed to prove by clear and convincing evidence that PAE was so totally incapable of providing for her own care or custody as to create a substantial risk of serious harm to herself or others.

Ozaukee County v. J.J.W., 2025AP1702, 6/3/26, District II (ineligible for publication); case activity

The COA affirmed the circuit court’s order continuing “Jacob’s” protective placement and determined the County did not need to establish a substantial risk of future harm by presenting evidence of previous harm identical to the harm that is anticipated.

Waukesha County Department of Health & Human Services v. C.O., 2025AP2640, 5/6/26, District II (ineligible for publication); case activity

COA affirms an order continuing “Cathy’s” protective placement based on concerns about her lack of independence and alcoholism.

Washington County v. J.E.C., 2025AP2798, 4/29/26, District II (ineligible for publication); case activity

COA relies on the respondent’s frequent absconding from her group home to find dangerousness and also holds that the existing Ch. 55 order is insufficient to meet J.E.C.’s needs.

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.