On Point: e. Dangerousness

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.

Winnebago County v. D.P., 2024AP2391-FT, 3/19/25, District II (1-judge decision, ineligible for publication); case activity

In appeal eerily similar to a SCOW case that was dismissed as improvidently granted, COA affirms and holds that the conclusory testimony supporting involuntary medication and recommitment was legally sufficient.

Winnebago County v. J.S., 2024AP1333, 3/5/25, District II (1-judge decision, ineligible for publication); case activity

In yet another case testing the applicability of SCOW’s D.J.W. mandate, COA finds that the circuit court “barely” satisfied those requirements and affirms.

Sheboygan County v. L.L., 2024AP1443, 2/26/25, District II (1-judge decision, ineligible for publication); case activity

COA confronts the usual challenges to a recommitment order and affirms based on a somewhat novel legal theory–that L.L.’s earlier stipulation to a commitment order undermines her sufficiency challenge to the recommitment.

Racine County v. C.D.B., 2024AP1195, 2/5/25, District II (1-judge decision, ineligible for publication); case activity

In “Banks’s” most recent appeal, he once again challenges the sufficiency of the evidence pertaining to his extension and medication orders. Like his last appeal, however, those arguments go nowhere.

Price County v. C.N.S., 2024AP853, District III, 1/22/25 (one-judge decision; ineligible for publication); case activity

Appellant CNS wins a battle but loses the war as the COA affirms the circuit court’s order extending her commitment under Ch. 51, but reverses order authorizing involuntary medication.  The Court clarified that a circuit court meets D.J.W.’s requirement to make a specific factual finding with reference to the subparagraph of Wis. Stat. § 51.20(1)(a)2. on which the recommitment is based if the circuit court’s oral ruling referred to the wording of the statute, even if the court did not cite the specific subparagraph.

Trempealeau County v. R.B., 2024AP1052, 12/10/24, District III (one-judge decision; ineligible for publication); case activity

COA affirms, holding that the evidence of potential deterioration during commitment period justified extension order.

Brown County v. R.J.M., 2024AP206, 5/7/24, District II (one-judge decision; ineligible for publication); case activity

Despite the doctor’s imprecise and generic testimony, COA holds that admission of his report resolves any deficiencies in the record and affirms.

Racine County v. C.B., 2023AP2018-FT, 3/20/24, District II (one-judge decision; ineligible for publication); case activity

In a factually-specific appeal of a recommitment order, COA rejects all of C.B.’s arguments and affirms.

Waukesha County v. G.M.M., 2023AP1359, 3/13/24, District II (one-judge decision; ineligible for publication); case activity

In an appeal presenting a straightforward D.J.W. claim, COA affirms while also giving credence to harmless error arguments.