By: Derek Hawkins//February 2, 2022//
WI Court of Appeals – District III
Case Name: Trempealeau County Department of Social Services v. T.M.M.,
Case No.: 2021AP100; 2021AP139
Officials: HRUZ, J.
Focus: Involuntary Commitment and Medication
Tiffany appeals from an order extending her involuntary commitment and an order for involuntary medication and treatment, both entered pursuant to WIS. STAT. ch. 51. Tiffany argues that the Trempealeau County Department of Social Services (“the County”) failed to establish that she was dangerous under any of the standards set forth in WIS. STAT. § 51.20(1)(a)2. She also challenges the circuit court’s determination that she was not competent to refuse medication or treatment. Finally, Tiffany argues that the court’s ruling at her recommitment hearing did not satisfy the requirements set forth in Langlade County v. D.J.W., 2020 WI 41, 391 Wis. 2d 231, 942 N.W.2d 277, because the court failed to identify the particular subdivision paragraph under § 51.20(1)(a)2. on which it based its dangerousness determination. We conclude that the County failed to present sufficient evidence to establish that Tiffany was dangerous under any of the legal standards set forth in § 51.20(1)(a)2. Accordingly, we reverse both orders.