On Point: 8. Appeals

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.

Grant County Dept of Social Services v. D.G.N., 2025AP2382, 2/27/26, District IV (ineligible for publication); case activity

In this appeal limited to the validity of an order for the involuntary administration of psychotropic medication in a guardianship case, COA holds that the county failed to meet two of the Wis. Stat. § 55.14(3) requirements.

V.K. v. D.J.F., 2024AP2028, 9/10/25, District II (ineligible for publication); case activity

COA ducks a recurrent issue as to whether expert testimony is required to prove the grounds for a protective placement and otherwise affirms the circuit court’s order granting this privately-filed petition for protective placement.

State of Wisconsin v. S.L.L., 2024AP551, 8/26/25, District I (ineligible for publication); case activity

S.L.L. failed to preserve an objection to a protective order as to the identity of the proposed adoptive resource, leading to a quick affirmance from COA.

Washburn County v. L.R.Y., 2025AP272-FT, District 3, 7/22/25 (one-judge decision; ineligible for publication); case activity

“Lily” appeals an original commitment and involuntary med order, arguing that the circuit court violated her right to have the County’s fact witnesses testify in person. COA agrees that, under Wis. Stat. § 885.60(2)(d), the circuit court erred by failing to sustain Lily’s objection to the county’s fact witnesses appearing by video at the final hearing.

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.

Waukesha County v. R.D.T., 2024AP1390, 2/12/25, District II (1-judge decision, ineligible for publication); case activity; petition for review granted 11/17/25

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

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.

State v. J.S.,, 2024AP180 & 2024AP181, 4/16/24, District I (one-judge decision; ineligible for publication); case activity

On appeal from TPR orders related to her two children, J.S. (“Julia”) raised two issues: whether the circuit court had personal jurisdiction over her and whether the circuit court erred by granting the GAL’s substitution request. The court of appeals makes short work of each argument because Julia forfeited the claims by not first raising either issue in the circuit court.