Involuntary Commitment and Medication-Inadmissible Hearsay

By: WISCONSIN LAW JOURNAL STAFF//September 18, 2023

WI Court of Appeals – District III

Case Name: Brown County v. Z. W. L.

Case No.: 2022AP002201

Officials: Gill, J.

Focus: Involuntary Commitment and Medication-Inadmissible Hearsay

Zeb appeals an order extending his involuntary commitment pursuant to WIS. STAT. § 51.20 and an associated order for involuntary medication and treatment. Zeb argues that the circuit court relied on inadmissible hearsay when it found that Zeb is dangerous under § 51.20(1)(a)2.b. and 2.c., and that this error prejudiced him because there was no other evidence to establish his dangerousness. The appeals court concludes that the court relied on inadmissible hearsay in finding that Zeb was dangerous, that no exceptions to the hearsay rule applied to permit the admission of the testimony, and that the admission of the hearsay testimony was prejudicial to Zeb.

Reversed.

Decided 09/12/23

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