On Point: b. Harm to others

Fond du Lac County v. K.L.W., 2026AP87, 7/15/26, District II (ineligible for publication); case activity

COA concludes that the county presented sufficient evidence to establish “Karrie’s” dangerousness and incompetence to refuse medication. Accordingly, it affirms both orders.

Racine County v. P.L., 2026AP132, 7/8/26, District II (ineligible for publication); case activity

COA rejects P.L.’s arguments that the county failed to introduce clear and convincing evidence to support a conclusion that he is dangerous under the second standard (via the recommitment standard) and the circuit court failed to make specific factual findings, and affirms.

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.

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.

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.

Fond du Lac County v. D.P.E., 2025AP66-FT, 4/30/25, District II (1-judge decision, ineligible for publication); case activity

COA affirms the circuit court’s orders recommitting D.P.E. (referred to as “Donald”) and authorizing the involuntarily administration of medication. Donald argued on appeal that the county did not present sufficient evidence to establish dangerousness and failed to meet its burden to prove he was not competent to refuse medication.

Trempealeau County v. C.B.O., 2024AP1520-FT, 2/4/25, District III (one-judge decision; ineligible for publication); case activity

COA affirms, holding that the evidence of a verbal threat to kill someone, and “Carl’s” actions during a subsequent police chase, were both sufficient to establish dangerousness under Wis. Stat. § 51.20(1)(a)2.b.

Monroe County v. M.C., 2024AP924, 12/12/24, District IV (one-judge decision; ineligible for publication); case activity

The Court of Appeals reversed the circuit court’s commitment order under Chapter 51 where the court did not make sufficient factual findings to support its conclusion that M.C. was dangerous, as required by D.J.W.