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Involuntary Commitment and Medication

By: WISCONSIN LAW JOURNAL STAFF//November 14, 2022//

Involuntary Commitment and Medication

By: WISCONSIN LAW JOURNAL STAFF//November 14, 2022//

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WI Court of Appeals – District III

Case Name: Marathon County v. T. J. M.

Case No.: 2022AP000623

Officials: Stark, P.J.

Focus: Involuntary Commitment and Medication

Trevor appeals two orders entered under WIS. STAT. ch. 51, one recommitting him for twelve months and another allowing for the involuntary administration of medication and treatment. Trevor argues that the orders should be reversed because the circuit court failed to make specific factual findings regarding his dangerousness under a subdivision paragraph of § 51.20(1)(a)2., as required by Langlade County v. D.J.W., 2020 WI 41, 391 Wis. 2d 231, 942 N.W.2d 277. Additionally, Trevor argues that Marathon County failed to present sufficient evidence demonstrating that he is dangerous. We assume without deciding that the court concluded that Trevor was dangerous under § 51.20(1)(a)2.a. and c., and (1)(am). The court concludes however, that the County failed to present sufficient evidence that Trevor is currently dangerous.

Reversed

Decided 11/08/22

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