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.
7th Circuit rejects facial challenge to § 971.17(4)(d)
Graham L. Stowe v. Gregory Van Rybroek, No. 23-3345, 8/21/24
This habeas appeal is limited to a facial challenge to the NGI conditional release statute, Wis. Stat. § 971.17(4)(d). The Seventh Circuit rejects Stowe’s argument, concluding that he cannot show that there are no circumstances under which the law’s application would be valid.