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Involuntary Commitment – Sufficiency of Evidence

WI Court of Appeals – District III

Case Name: Trempealeau County v. C.B.O.

Case No.: 2021AP1955, 2022AP102

Officials: STARK, P.J.

Focus: Involuntary Commitment – Sufficiency of Evidence

In these consolidated appeals, Chris appeals from an order committing him under WIS. STAT. ch. 51 and from an order extending his commitment for an additional year. Chris argues that both orders should be reversed because Trempealeau County (the County) failed to present sufficient evidence that he is dangerous pursuant to WIS. STAT. § 51.20(1)(a)2. at both his initial commitment and recommitment hearings. Chris also asserts that the circuit court, at his commitment hearing, failed to make specific factual findings with reference to the subdivision paragraph of § 51.20(1)(a)2. under which it found Chris to be dangerous, as required by our supreme court in Langlade County v. D.J.W., 2020 WI 41, 391 Wis. 2d 231, 942 N.W.2d 277. We agree that the court failed to make the specific factual findings required by D.J.W. at Chris’s commitment hearing and that the County did not present sufficient evidence to establish that Chris is dangerous during either his initial commitment or recommitment proceedings. Accordingly, we reverse both orders.


Decided 08/30/22

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