On Point: b. Harm to others

Milwaukee County v. Cheri V., 2012AP1737, District 1, 12/18/12

 court of appeals decision (1-judge, ineligible for publication); case activity

Mental health commitment, § 51.20, requires proof of mental illness and dangerousness. Cheri V. limits this challenge to the latter; the court agrees:

¶7        As seen from our recitation of the facts adduced at the trial, however, there is absolutely no evidence that any of the statutory prerequisites were met—yelling at and pointing a finger at another person,

Manitowoc County v. Harlan H., 2011AP2499-FT, District 2, 1/25/12

court of appeals decision (1-judge, not for publication); for Harlan H.: Shelley Fite, SPD, Madison Appellate; case activity

Evidence that Harlan had put his wife in a headlock on one occasion and physically resisted a deputy’s attempt to detain him another, coupled with a diagnosis of paranoid schizophrenia, held sufficient to support ch. 51 commitment.

¶6        Wisconsin Stat. 

Outagamie County v. Lorna G., 2011AP1662, District 3, 10/25/11

court of appeals decision (1-judge, not for publication); for Lorna G.: Eileen A. Hirsch, SPD, Madison Appellate; case activity

Although the trial court’s reference to “potential” for harm was an “imprecise summary” of the §51.20(1)(a)2b test for commitment (“substantial probability of physical harm”), this articulation “was not a deviation from the” correct standard. Moreover, the trial court’s finding that Lorna G.

Barron County v. Dennis H., 2010AP1026, District 3, 10/19/10

court of appeals decision (1-judge, not for publication); for Dennis H.: Jefren E. Olsen, SPD, Madison Appellate

Evidence held sufficient to support finding of dangerousness.

1) Recent overt act, attempt or threat to do serious physical harm. A psychologist testified that Dennis at times displayed aggressive behavior (“he changes at the snap of the finger and will become highly excitable,