On Point blog, page 1 of 1
COA affirms 51.20 commitment for alcoholism as matter of first impression
Vernon County v. F.W.R., 2024AP203, District IV, 11/6/24 (one-judge decision; ineligible for publication); case activity
COA rejects F.W.R.’s challenges to his involuntary commitment order under Wis. Stat. § 51.20 for alcohol dependence, concluding that a person may be involuntarily committed for treatment for alcoholism, the circuit court followed the proper procedures and the county met its burden to prove that he was drug dependent and dangerous.
Evidence at recommitment hearing established mental illness and dangerousness under 3rd standard
Waukesha County v. G.M.M., 2022AP1207, 1/18/23, District 2, (1-judge opinion, ineligible for publication); case activity
This appeal involves a recommitment under the 3rd standard of dangerousness. G.M.M. argued that the county presented insufficient evidence of both mental illness and dangerousness. She also argued that the circuit court failed to make the findings required under Langlade County v. D.J.W., 2020 WI 41, ¶59, 391 Wis. 2d 231, 942 N.W.2d 277. The court of appeals rejected all 3 claims.
Evidence sufficient to prove elements of ch. 51 commitment
Outagamie County v. D.G.M., 2020AP967, District 3, 9/21/21 (one-judge decision; ineligible for publication); case activity
The evidence at the final hearing on the petition to commit D.G.M. under ch. 51 was sufficient to establish all the statutory elements and D.G.M.’s incompetence to refuse medication.
Jury instruction defining “drug” using dictionary was proper in ch. 51 commitment based on drug dependency
Marathon County v. Zachary W., 2014AP955, District 3, 12/2/14 (1-judge decision; ineligible for publication); case activity
Even if the circuit court erred it provided multiple definitions of the term “drug” when instructing the jury hearing a ch. 51 commitment case.
No specific diagnosis, but evidence sufficient to support recommitment and involuntary medication
Brown County v. Quinn M., 2010AP3162, District 3, 4/26/11
court of appeals decision (1-judge, not for publication); for Quinn M.: Chandra N. Harvey, SPD, Madison Appellate; case activity
Evidence held sufficient to support extension of ch. 51 commitment upheld. 1. Mental illness. Expert testified that she was certain Quinn had a mental illness, though given his history of drug and alcohol use she could not provide a specific diagnosis with certainty.