On Point: 2. Recommitment

Waukesha County v. R.D.T., 2024AP1390, 2/12/25, District II (1-judge decision, ineligible for publication); case activity

COA dismisses “Rex’s” D.J.W. and sufficiency challenges to his 2023 recommitment and involuntary medication orders as moot.

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.

Waukesha County v. M.A.C., 2024 WI 30, 7/5/24, reversing an unpublished court of appeals decision; case activity (including briefs)

In a big defense win, 6 justices agree that M.A.C. is entitled to relief, with four justices joining together to dismantle SCOW’s prior decision in S.L.L. with respect to notice and default judgment in Chapter 51 proceedings.

Marathon County v. N.R.P., 2023AP638, 6/11/24, District III (one-judge decision; ineligible for publication); case activity

In yet another Chapter 51 reversal, COA finds fault with both the circuit court’s decision to admit and rely on hearsay evidence and its failure to make the required findings.

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. P.Z., 2024AP146-FT, 5/1/24, District II (one-judge decision; ineligible for publication); case activity

In a relatively straightforward appeal of a recommitment order, COA rejects P.Z.’s sufficiency challenges 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.