On Point blog, page 1 of 1
COA holds that protective placement may be continued based on evidence from previous hearings provided the evidence was “adjudicated.”
Pierce County v. P.C.A., 2024AP1367, 7/1/25, District III (ineligible for publication); case activity
While affirming the circuit court continuing a protective placement order under Chapter 55 after a due process hearing (known as a Watts hearing), the COA clarified that, following previous due process hearings, documentary evidence that was admitted, and testimony that was accepted by the circuit court and incorporated into its findings, may be considered at subsequent due process hearings.
COA rejects sufficiency challenges in 51 appeal and affirms
Waukesha County v. J.A.K., 2024AP2535, 6/25/25, District II (ineligible for publication); case activity
In yet another Chapter 51 appeal, COA rejects the usual arguments and affirms.
Excessive water intake sufficient to find person “dangerous” under Chapter 51.
Winnebago County v. J.M., 2024AP1554, 4/2/25, District II (1-judge decision, ineligible for publication); case activity
COA affirmed the circuit court’s order recommitting J.M. (referred to as “James Moore”) for twelve months and authorizing involuntarily administering medication. The Court found that Moore suffers from schizoaffective disorder, which caused him to drink an excessive amount of water to the point that he needed to be transported to the emergency room for low sodium levels in his body. The Court therefore found that Moore is a danger to himself, and that he is a proper subject for treatment because his condition is treatable with medication.