On Point: A. Ch. 51, Mental health

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.

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.

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.

Outagamie County v. R.M.R., 2025AP561, 11/18/25, District III (ineligible for publication); case activity

In a strong defense win, COA rejects the County’s arguments and holds that the evidence is insufficient to support this medication order as the County failed to name the particular medication it sought to involuntarily administer.

Trempealeau County v. S.K., 2025AP645, 11/4/25, District III (ineligible for publication); case activity

The COA reversed the circuit court’s order to extend “Sharon’s” involuntary commitment.  Although the County presented evidence that Sharon would stop taking medication to treat her schizophrenia if she were not committed, the evidence to support her current dangerousness was conclusory.

Outagamie County v. M.J.B., 2024AP250, petition for review of a published decision of the court of appeals, granted 10/6/25; case activity

SCOW granted Outagamie County’s petition for review to address whether an examiner’s report filed less than 48 hours in advance of the final hearing is inaccessible for purposes of Wis. Stat. § 51.20(10)(b), which provides that “[c]ounsel for the person to be committed shall have access to all psychiatric and other reports 48 hours in advance of the final hearing.” 

V.K. v. D.J.F., 2024AP2028, 9/10/25, District II (ineligible for publication); case activity

COA ducks a recurrent issue as to whether expert testimony is required to prove the grounds for a protective placement and otherwise affirms the circuit court’s order granting this privately-filed petition for protective placement.

Grant County v. T.L.M., 2025AP500, 8/28/25, District IV (ineligible for publication); case activity

T.L.M. challenges her recommitment, arguing that the circuit court erroneously admitted hearsay evidence over her objection, and that the court failed to make the required factual findings to support the commitment. COA concludes that although the circuit court erroneously admitted some hearsay, the error was harmless, and that the circuit court satisfied the demands of Langlade County v. D.J.W., 2020 WI 41, 391 Wis. 2d 231, 942 N.W.2d 277.

Brown County v. M.J., 2025AP116, 8/26/25, District III (ineligible for publication); case activity

In a Chapter 51 appeal presenting familiar legal challenges, COA avoids some of the stickier legal issues on a path toward affirmance.