On Point: A. Ch. 51, Mental health

Sheboygan County v. N.A.L., 2026 WI 16, 5/19/26, affirming an unpublished decision of the court of appeals; case activity

In a relatively concise majority opinion, SCOW addresses a narrow issue and holds that no colloquy is required when a person stipulates to an involuntary mental commitment order. However, the separate writings flag many other interesting and highly relevant issues for our readers.

Winnebago County v. E.R.B., 2025AP2522, 5/14/26, District IV (ineligible for publication); case activity

COA affirms the circuit court’s orders extending ERB’s commitment and authorizing his involuntary medication and treatment, concluding that there was sufficient evidence to sustain the commitment order, and that the medication order is moot, as it previously expired.

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commitment because there was a substantial likelihood he would be a proper subject for commitment if treatment were withdrawn given his history of not taking medication for schizoaffective disorder unless court ordered.

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.

Jackson County v. D.C., 2025AP1838 & 2025AP1839, 4/23/26, District IV (ineligible for publication); case activity

The COA reversed D.C.’s commitment order and the order extending his commitment because the County did not meet its burden to establish he was dangerous.

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.

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.