Involuntary Commitment

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WI Court of Appeals – District III

Case Name: Marinette County v. C. R. J.

Case No.: 2023AP001695-FT

Officials: Stark, P.J.

Focus: Involuntary Commitment

Caleb appeals an order for his involuntary commitment pursuant to WIS. STAT. § 51.20 and an order for his involuntary medication pursuant to WIS. STAT. § 51.61(1)(g). Caleb argues that the circuit court erred by failing to make specific factual findings regarding his dangerousness and that Marinette County presented insufficient evidence to prove that he was dangerous pursuant to either § 51.20(1)(a)2.a. or b.

The appeals court concludes that the circuit court failed to make any specific factual findings regarding how Caleb evidenced a substantial probability of harm to others as required under WIS. STAT. § 51.20(1)(a)2.b. The appeals court assumes without deciding that the court made sufficient factual findings regarding Caleb evidencing a substantial probability of harm to himself under § 51.20(1)(a)2.a. However, the appeals court concludes as a matter of law, that the County presented insufficient evidence to support those findings.

Reversed.

Decided 04/16/24

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