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Involuntary Commitment – Sufficiency of Evidence

WI Court of Appeals – District III

Case Name: Outagamie County v. L.C.E.,

Case No.: 2021AP324

Officials: HRUZ, J.

Focus: Involuntary Commitment – Sufficiency of Evidence

Lauren appeals from an order extending her involuntary commitment under WIS. STAT. ch. 51 and an order for involuntary medication and treatment. Lauren argues that the circuit court’s ruling at her recommitment hearing failed to identify the subdivision paragraph(s) under WIS. STAT. § 51.20(1)(a)2. on which it based its dangerousness determination, in contravention of Langlade County v. D.J.W., 2020 WI 41, 391 Wis. 2d 231, 942 N.W.2d 277. Lauren also challenges the sufficiency of the evidence establishing that she was currently dangerous under any of the standards set forth in § 51.20(1)(a)2. We agree that the court failed to make the specific findings mandated by D.J.W., and we therefore reverse.

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Derek A Hawkins is Corporate Counsel, at Salesforce.

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