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Involuntary Commitment

WI Court of Appeals – District III

Case Name: Barron County v. K. L.

Case No.: 2022AP000502

Officials: Gill, J.

Focus: Involuntary Commitment

Katie appeals a WIS. STAT. ch. 51 recommitment order and an order for involuntary medication and treatment. Katie argues that the evidence presented by Barron County was insufficient to prove that she was dangerous. Katie further argues that the circuit court’s findings were insufficient to establish dangerousness and violated the requirements of Langlade County v. D.J.W., 2020 WI 41, 391 Wis. 2d 231, 942 N.W.2d 277.

The appeals court disagrees as to both issues. The County met its burden to prove Katie was dangerous by clear and convincing evidence under WIS. STAT. § 51.20(1)(a)2. d. Additionally, the circuit court explicitly found in its written order that Katie was dangerous under § 51.20(1)(a)2. d.


Decided 02/07/23

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